AUSTRALIAN ANIMAL WELFARE
STANDARDS AND GUIDELINES
FOR
SHEEP
Public Consultation Response
Action Plan
May 2014
DISCLAIMER
This publication is published by Animal Health Australia (AHA) for information
purposes only. Information contained in it is drawn from a variety of sources
including some external to AHA. Although reasonable care was taken in its
preparation, AHA does not guarantee or warrant the accuracy, reliability,
completeness, or currency of the information or its usefulness in achieving any
purpose.
To the fullest extent permitted by law, AHA will not be liable for any loss, damage,
cost or expense incurred in or arising by reason of any person relying on the
information in this publication. Persons should accordingly make and rely on their
assessments and enquiries to verify the accuracy of the information provided.
Copyright
This publication is protected by copyright. Information or material from this
publication may be reproduced in unaltered form for personal, non-commercial use.
All other rights are reserved. Information or material from this publication may be
used for the purposes of private study, research, criticism or review permitted under
the Copyright Act 1968.
Any reproduction permitted in accordance with the Copyright Act 1968 must
acknowledge AHA as the source of any selected passage, extract, diagram or other
information. Any reproduction must also include a copy of the original copyright and
disclaimer notice as set out here.
Commercial and other use
No part of this publication may be reproduced, stored in a retrieval system,
distributed or commercialised in any form without prior written approval from AHA.
The contents of the publication may not be used to sell a product or service for
commercial reasons such as advertising.
Trade marks
Any trade marks or logos contained in this publication may not be used without the
prior written permission of AHA.
ISBN 978-1-921958-21-2
TABLE OF CONTENTS
DISCLAIMER
Copyright
Commercial and other use
Trade marks
2
2
2
2
TABLE OF CONTENTS
3
EXECUTIVE SUMMARY
5
SUMMARY OF RIS VARIATIONS AND RECOMMENDATIONS
6
DOCUMENT PURPOSE
8
CONSULTATION PROCESS
9
INDEPENDENT CONSULTANT
9
MAJOR WRITTEN SUBMISSIONS - CONTENTIOUS AND POPULAR ISSUES
9
ON-LINE SURVEY
11
EMAIL LETTER SUBMISSIONS
12
REGULATION IMPACT STATEMENT
13
Background
RIS Submissions
RIS options organisational position summary table
Summary of On-line Survey RIS questions
On-line survey RIS options
On-line survey questions related to the RIS process
Summary of responses
Survey questions relating to the public consultation process
Actions
INTERNATIONAL STANDARDS
General issues
SCOPE – RELATIONSHIP BETWEEN THE STANDARDS AND GUIDELINES
General standards – language and construction
Definitions
Consistency in legislation, monitoring and enforcement
Independence and credibility of the standards development process
Decision making
Post consultation process
Future communication and extension
SPECIFIC ISSUES BY CHAPTER
13
14
18
18
19
20
20
21
25
25
26
27
28
30
30
31
33
33
35
36
Chapter 1 Responsibilities
Chapter 2 Feed and Water
Chapter 3 Risk Management
Chapter 4 Facilities and Equipment
Chapter 5 Handling and Husbandry
Chapter 6 Tail Docking and Castration
Chapter 7 Mulesing
Chapter 8 Breeding Management
Chapter 9 Intensive Sheep Production Systems
Chapter 10 Humane killing
36
39
42
46
48
56
61
67
70
74
APPENDIX 1 - LIST OF NOTED SUBMISSIONS AND ACRONYMS
80
APPENDIX 2 - PICTORIAL REPRESENTATION OF STANDARDS AND GUIDELINES
DEVELOPMENT PROCESS
83
EXECUTIVE SUMMARY
This document is based on summarised submissions received for the draft standards
and guidelines for sheep (May 2014) and the associated Consultation Regulation
Impact Statement (RIS). The document identifies where there is a need or a desire
for change in the standards and guidelines and if agreed, how this might be
accomplished. It follows the format of the proposed standards and guidelines where
possible. Specific issues are presented in the context of background information of
relevance (the proposed standards), submissions and considerations (including cross
reference to the Consultation RIS) and proposed actions.
Acknowledgment is given to Ms Kelly Wall, Animal Health Australia Project Officer
and Dr Robin Vandegraaff of Animal Health and Welfare Systems who performed the
initial analysis and summary of the submissions. This document initially functioned as
a comprehensive summary and analysis of submissions for the writing and reference
groups and will now be published as a record of decisions and recommendations
made at the final reference group meeting. Tracked changes to standards and
guidelines have been preserved to illustrate changes proposed or accepted.
Fifty four substantial submissions have been received relating to the draft standards
and guidelines and the RIS. These have been analysed and are reported on in this
document. 965 on-line questionnaires have also been completed with results
reported against relevant topics. In addition approximately 13,850 email letters have
been received, of which the vast majority supported notions of better welfare
standards.
Submitters will not be responded to directly. Only organisational submissions are
identified in this report unless there is particular merit in the individual’s submission.
Submissions published or quoted are listed at Appendix one.
It has not been possible to generally recognise individual submissions in this report.
In all cases the concerns raised by individuals have been also raised by
organisations, and therefore the issues have been identified in this report.
Acknowledgement is generally given to the degree of interest and effort that has
gone into these submissions and in particular, the ongoing participation by RSPCA
Australia and Animals Australia throughout the development process.
The (proposed) categorisation and handling of issues identified in the public
consultation is described. The four main decision-making principles used for
standards are that they are desirable for livestock welfare, feasible for industry and
government to implement, important for the livestock-welfare regulatory framework
and will achieve the intended outcome for livestock welfare.
The combined writing groups considered a summary analysis of the many detailed
submissions to the public consultation of the standards and guidelines for sheep and
cattle.
They then closely considered the draft documents and decided there were only minor
changes required on the basis of the justification provided.
Page | 5
There was recognition of prior process where many of the issues had been
comprehensively considered in previous writing and reference group meetings. It was
decided not to further update the discussion papers used in consultation.
Reference group discussions determined that there was little justification needed,
with limited science or no scientific practical basis in response to the submissions. A
small number of edits have been made, including ensuring the language has been
made consistent across the documents.
A number of draft guidelines were proposed for elevation to standards however these
were not generally progressed because they failed to meet one or more of the
decision making principles.
This approach was generally supported by the reference group but consensus was
not reached on all issues, including on the major variations proposed in the RIS. It
was decided to proceed independently with all RIS variations in the Decision RIS for
a total of seven options.
SUMMARY OF RIS VARIATIONS AND RECOMMENDATIONS
RIS Variation
C1: All Mulesing with pain
relief
C2: Restrict Mulesing age
to less than 6 months of
age
C3: Single penning for
wool production ban
Recommendation Recommendation Comment
as a new
as a RIS Variation
standard
Not supported
Supported
See Chapter 7 for
further discussion
Not supported
Supported
See Chapter 7 for
further discussion
Supported
C4: Tethering ban
Not supported
No longer
separately
required in the
RIS.
Supported
C5: Mandate pain relief
for ET/LAI
C6: Require docked tails
to have at least one free
palpable joint
Not supported
Supported
Supported
S5.1 A (short version)
Supported
No longer
separately
required in the
RIS.
Supported
See Chapter 9 for
further discussion
See Chapter 5 for
further discussion
See Chapter 8 for
further discussion
See Chapter 6 for
further discussion
See Chapter 5 for
further discussion
The public consultation process has resulted in two new standards, revision to 10
standards and revision to, and inclusion of, 18 guidelines. The overall
recommendations from the reference group to governments is to consider
Page | 6
endorsement of the documents based on the revised proposed standards and
guidelines.
Kevin de Witte
Animal Health Australia,
May 2014
Page | 7
DOCUMENT PURPOSE
This document provides a summary of submissions received during the five month
long public consultation period for the draft Australian Animal Welfare Standards and
Guidelines for Sheep and the associated Consultation RIS, and the subsequent
consideration of these documents by the writing and reference groups.
The document also identifies any recommendation for change in the standards and
guidelines resulting from the public consultation process and proposes to government
how this might be accomplished. Associated documents are the revised Australian
Animal Welfare Standards and Guidelines for Sheep and the Decision RIS.
The Australian Animal Welfare Standards and Guidelines - Sheep (‘the proposed
standards’) form the basis for legally enforceable standards for the welfare of all
sheep, in all types of farming enterprises in Australia. They will apply to all those with
responsibilities for the care and management of sheep. It is intended that the
proposed standards and guidelines will replace the existing Model Code of Practice
for the Welfare of Animals – Sheep (‘the existing code’).
The development of nationally consistent animal welfare arrangements for various
industry sectors has been identified as a major priority by all levels of government,
industry and welfare organizations. In addition it is a key policy objective under the
Australian Animal Welfare Strategy (AAWS). The AAWS has identified enhanced
national consistency in regulation and sustainable improvements in animal welfare
based on science, national and international benchmarks and changing community
standards as areas of priority effort.
The RIS process assessed the proposed standards in accord with the requirements
of the Council of Australian Governments. The RIS was also used to facilitate public
consultation on the proposed standards. The RIS was prepared for AHA by Tim
Harding & Associates in association with Rivers Economic Consulting.
Major actions from the post consultation development process are summarised in the
executive summary. Detailed discussion on all actions arising from the public
consultation can be found in the relevant part of this document.
Page | 8
CONSULTATION PROCESS
An open public consultation ran from 7 March – 5 August 2013. Government
Minister’s for Agriculture directed that consultation be extended from the agreed 60
days for a further 90 days just before the initial closure.
Media releases from AHA occurred prior and during the consultation period. Paid
advertisements were placed in larger regional newspapers and one major weekend
newspaper just prior to 7 March. At that time, reference group organisations
(government, industry and welfare) were asked to duplicate and disseminate the
prepared messages through their own networks and resources. Organisations were
encouraged to consult with their members and to maintain a log of all related
activities. AHA maintained updates on the AHA website and at the consultation site
www.animalwelfarestandards.net.au. In most cases the complementary efforts were
timely and helpful.
Three categories of submission were received: substantial written documents, part or
full completion of an online survey, with or without additional comments and email
letters, many in a similar format. AHA preferred respondents to forward written
comments electronically. Submissions were made via the website, email, fax or post.
The web based survey was available at the following site:
http://www.animalwelfarestandards.net.au.
All submissions will be treated as public documents. Written submissions from
organisations and substantial submissions from individuals are published on the
website www.animalwelfarestandards.net.au.
INDEPENDENT CONSULTANT
Dr Robin Vandegraaff of Animal Health and Welfare Systems was contracted to
independently examine and summarise written and on-line survey submissions to the
public consultation process for the Australian Animal Welfare Standards and
Guidelines for Sheep. His report made observations, conclusions and
recommendations to AHA for consideration by the writing and reference groups.
MAJOR WRITTEN SUBMISSIONS - CONTENTIOUS AND
POPULAR ISSUES
General comments in the 44 major written submissions, unrelated to specific standards
or guidelines, contained some common themes. They were
1. Criticism (mostly by welfare advocates and lawyer groups) of the use of
“general” standards and subjective terms such as “reasonable”, “adequate” and
“appropriate” – covered under ‘language and construction’ below;
Page | 9
2. Concern (mostly in livestock industry organisations) about the capacity and
commitment of government regulatory authorities to monitor and enforce
compliance, and the consistency of enforcement by states and territories;
3. The practical difficulties in compliance with pain relief, veterinary procedures
and age limits in extensive sheep production systems;
4. Concern and mistrust in some industry groups about the potential for courts to
prosecute on the basis of failure to comply with guidelines – covered under
‘scope’ below;
5. The perceived lack of specificity (by welfare advocates) in some standards and
their preference for adopting guidelines as standards;
The most controversial issues related to individual draft standards were:
1. Mulesing (S7.2)
o calls for prohibition
o with pain relief in all ages
o age limits – various ages suggested
2. Pain relief for other surgical procedures
o castration, tail docking (S6.2, S6.4)
o mandate pain relief irrespective of age (welfare/rights groups)
o mandate at any age is impractical (producer groups)
o artificial breeding procedures (S8.1)
o veterinary only (welfare groups)
o convert G8.12 (training) and/or G8.14 (analgesia) to a standard
3. Availability of water daily (S2.1) – non-acceptance of “reasonable access”
4. Provision of shelter (G3.6, suggested should be converted to a standard)
5. Slaughtering of sheep
o by head trauma (S10.5)
o slaughter by bleeding out (S10.6)
These issues were highlighted most frequently in written submissions and
characterised by an “agreement” rate of less than 70%, and/or attracting the greatest
number of comments in the on-line survey. Further discussion on these topics occurs
as relevant in each chapter below.
Page | 10
ON-LINE SURVEY
The on-line survey sought responses on each of the 37 draft standards - specifically,
whether or not the Standard would benefit the welfare of sheep – and on the 26
questions raised in the Regulatory Impact Statement.
There were 965 responses to the survey. An average of 579 (60%) commented on
the welfare standards. The survey has been criticised for its low value, length and the
confusing nature of the questions but it is still supported by some survey respondents
as a means of consultation. The overall view is that the survey has added little to the
overall process with views expressed being consistent with other material and no
new facts emerging.
Of the 37 survey questions seeking a response on the overall benefit of the
standards, 34 returned a rating of “Agree” or strongly agree” of 70% or higher,
including 13 rating 80% or higher. The generic question, Q3 “Will the sheep welfare
standards help protect the welfare of sheep?” returned the lowest approval rating,
with 39% “Agree” or “Strongly agree”, and 51% “Disagree” or “Strongly disagree”.
This is an interesting outcome, repeated in the cattle survey, considering the high
“agreement” rating for the majority of individual standards.
Three draft standards returned an “agreement” rating of less than 70% - they were:

S7.2 – age limits for mulesing (“agreement” rating of 69%)

S10.5 – slaughter of lambs by head trauma (“agreement” rating of 54%)

S10.6 – slaughter of sheep by bleeding out (“agreement” rating of 55%)
The large number of comments made by respondents on these questions generally
reflected the views presented in written submissions.
Generic question (Survey Q3): Will the sheep welfare standards help protect the
welfare of sheep?
No. of
responses
677
% Agree
% Disagree
% Neutral
No. of comments
39
51
10
249
The 249 comments fell into 8 categories. The following table gives the percentage of
comments by category in a sample of 100 responses.
Category
Endorsement
Number of comments
11
Partial Improvement
16
If well enforced
15
Page | 11
Inadequate-unenforceable (single or limited issue)
34
Other
2
Informal
22
TOTAL
100
Many category 1 responses (the “inadequate-unenforceable” category) reflected
misinterpretation of the question, disregarding the word “help” and targeting one or
more specific welfare issues.
Q4: Is the first of several directional questions throughout the survey asking “Do you
wish to answer questions or provide further comment on the sheep welfare
standards?” The respondent would then be taken to the relevant section of the
survey.
Q5: Will S1.1 - "A person must take reasonable actions to ensure the welfare of
sheep under their care", help protect the welfare of sheep?
No. of
responses
650
% Agree
% Disagree
% Neutral
No. of comments
72
22
6
227
It is not intended to publish further detail for the survey, except in relation to the RIS.
EMAIL LETTER SUBMISSIONS
Approximately 13,850 email letters have been received, of which the vast majority
supported better welfare standards. In many cases objections to specific standards or
practices were raised, but few new alternatives to achieve sheep husbandry
outcomes were proposed. Many email submissions sought to compare the treatment
of livestock with that of urban companion animals.
The majority of concerns focused on daily access to water, shelter/shade provisions
and pain relief for all surgical procedures. Many submissions raised concerns that the
standards and guidelines for sheep will not protect them from cruelty, still allowing
workers to strike animals (in a reasonable manner) and use electric prodders (under
specified conditions).
Submissions expressed concern that sheep can still be subjected to mulesing and
artificial breeding practices, considered by many submitters to be dangerous and
unnecessary for sheep welfare.
Email submissions repeatedly stated that sheep are just as capable of feeling pain
and fear as any other animal and alleged that the standards do not reflect the
Page | 12
growing community concern about animal welfare, or the values society holds about
how these animals should treated.
Numerous submissions reflected concern about the cost to farmers and suggested
that if costs were reduced, farmers could provide better welfare. E.g. “More and more
our farmers are seeing their marginal profits squeezed out of them by Coles and
Woolworths... so every cent has to be gleaned from somewhere... goodbye animal
welfare”.
REGULATION IMPACT STATEMENT
Background
A key aspect to creating animal welfare standards is to identify the costs and benefits
that the proposal will have for a wide range of stakeholders. This is typically done by
preparing a RIS, as required by COAG, to assist final decision making state and
territory by governments.
A RIS is prepared by the department, agency, statutory authority or board
responsible for a regulatory proposal. The RIS for the standards and guidelines for
sheep has been developed by AHA in conjunction with the reference group. The RIS
includes recommendations for the most effective and efficient option and formalises
and documents how authorities have assessed the costs, benefits and the possible
changes to an existing (or a new) regulation. There are a number of assumptions and
limitations recognised in this complex and lengthy document. In general terms, the
RIS is accepted to be sufficiently accurate for the intended purpose as a guide to
decision making.
Authorities are required to conduct public consultation to seek feedback and
determine the level of support for the RIS. When the RIS is assessed, it must include
a consultation statement that shows how consultation was undertaken, who was
consulted and a summary of their views, and how those views that were considered.
The RIS consultation summary will be based upon this report.
Importantly the RIS considered alternative options and variations to the standards in
terms of costs and benefits. These were:

Option A: Converting the proposed national standards into national voluntary
guidelines (the minimum intervention option);

Option B: The proposed national standards as currently drafted;

Option C: One or more variations of the proposed national standards as follows:
C1 - All Mulesing with pain relief
C2 – Restrict Mulesing age to less than 6 months of age
C3 – Single penning for wool production ban
Page | 13
C4 – Tethering ban
C5 - Mandate pain relief for ET/LAI
C6 - Require docked tails to have at least one free palpable joint.
The reference group agreed that four options would be retained and one additional
variation included for final consideration. Agreement was not reached on a
recommended option. Further detail is provided below in the specific issues by
chapter sections.
RIS Submissions
In relation to the on-line survey; of the 965 respondents, only approximately 90 went
on to answer the specific RIS questions towards the end of the survey. These limited
results indicated no clear picture in regard to the preferred options, other than
general support for the all of the RIS variations under option C to be considered.
Further details are provided in the relevant chapters. Very few informative comments
were made. Further specific details will be reported in the Decision RIS. No further
variations were supported.
Copies of the written submissions are available at;
http://www.animalwelfarestandards.net.au/cattle/submissions/
In general terms the 17 animal welfare/rights groups supported Option C
(Variations C1-C6) as presented in the RIS; in addition several suggested further
variations. For example Sentient proposed additional variations – proposing a phase
out of all mulesing and mandating pain relief for all surgical procedures. These
proposals are discussed in the relevant chapters. No further variations were
supported.
RSPCA Australia suggested the RIS does not take into account the extent to which
compliance costs can be internalised and passed on through the supply chain. The
costs of higher welfare options proposed in the RIS are all attributed to ‘sheep
farmers’ alone. The RSPCA claimed the RIS discounts the ability of sheep farmers to
internalise these costs, and the steady increase in demand and market share for
higher welfare products, distorting the perception of how the economic impacts may
be distributed.
The RSPCA also challenged the statement in the RIS that Tri-Solfen is a Schedule 4
drug, only available through a veterinarian and therefore difficult to obtain. Rescheduling of the three active ingredients will make Tri-Solfen a Schedule 5 drug
from February 2014, so it will be readily available to mulesing operators.
Some written submissions made specific comments on statements and assumptions
in the RIS. For example the RSPCA Australia expressed concern that “the RIS does
not appear to take into account the extent to which compliance costs can be
internalised and passed on through the supply chain. The costs of higher welfare
options proposed in the RIS are all attributed to ‘sheep farmers’ alone. The RIS
Page | 14
appears to play down the ability of sheep farmers to internalise these costs simply on
the basis that ‘the market share for other animal welfare-related products indicates
that only a small percentage of consumers would be likely to be influenced in their
purchasing decisions. This ignores the steady year-on-year increase in demand and
market share for higher welfare products, and subsequently, distorts the perception
of how the economic impacts may be distributed”.
Twenty two Sheep industry organisations (notably AgForce, AMIC and ALRTA)
and many individual producer submissions generally supported Option B and
opposed all the variations.
WPA supports the adoption of national Standards as mandatory underpinned by
unenforceable Guidelines.
WPA supports the Standards with some amendments as proposed in Edition 1,
Public Consultation Version 1.0 of the Australian Animal Welfare Standards and
Guidelines – Sheep.
WPA proposes the conversion of parts of S5.1 and entire S6.2 and S6.4 to
Guidelines, the removal of S10.5 and S10.6 A and the amendment of S5.3. The
variations are not supported except for a simpler S5.1. and noting that C3 single
penning restrictions became S9.7 and C6 tail length to be one palpable free joint
became S6.3, as subsequently incorporated in the amended in Option B. No
preference for any option was stated.
SCA expressed sentiments that supports the adoption of national Standards as
mandatory underpinned by unenforceable Guidelines but raised a number of
concerns around implementation and harmonisation.
SCA proposes the conversion of parts of S3.2 and S5.1 to Guidelines, the removal of
S10.6 A and the clarification of export facility exclusion and the term ‘cryptorchidism’.
The variations are not supported except for a simpler S5.1. and noting that C6 tail
length to be one palpable free joint became S6.3, as subsequently incorporated in
the amended in Option B. No preference for any option was stated.
In response to the written submissions from SCA and WPA regarding S5.1, a new
Option C7 was included in this Decision RIS. This option would omit standard S5.1b
which lists various ways in which the manner of handling sheep would be considered
unreasonable.
While broadly stating their opposition to all variations and presenting specific
arguments against these. VFF, WAFF, SCA, AgForce and WPA all supported
Variation C6 with Victorian Farmers Federation stating their belief that Concern that
accurately tail docking to two joint is difficult to replicate and the production
preference for some producers for one joint for several reasons including to lessen
time and stress at crutching. VFF believe this will be of no detriment to animal welfare
and this is supported by the RIS which documents that there is no variation in welfare
benefit between tail docking at either one, two or three joints.
Page | 15
NSW Farmers supported Option A because it was “not convinced that an additional
layer of regulation will actually improve animal welfare outcomes as intended. The
vast majority of producers already ensure that the welfare of animals in their care is
upheld and for the minority of cases where this does not occur there is already
legislation, the Prevention of Cruelty to Animals Act, which can be used to enforce
minimum standards.” NSW Farmers’ submission included specific arguments
opposing Variations C1, C2 and C5 and supporting Variation C6. It also suggested
the RIS failed to recognise that many husbandry practices (including mulesing) are
carried out to mitigate or prevent endemic diseases which, in the view of NSW
Farmers, have more welfare effects than preventive husbandry practices.
The Australian Association of Stud Merino Breeders (AASMB) also supported Option
A and opposed Option B and all variations under Option C. Its position was based on
mistrust of the 2009 Primary Industries Ministerial Council (PIMC) Resolution (that
Guidelines will not be regulated) and the statement in the draft standards and
guidelines for sheep that noncompliance with one or more guidelines will not
constitute an offence under law. The AASMB’s concern here is “not primarily one of
fear of prosecution of its members or their clients per se but that the pursuance of
this strategy would prepare a pathway for opponents of agriculture to advance their
social / political agendas, wasting valuable community and industry resources with no
benefit to the animal.”
The TFGA’s submission indicated conditional support for Option B and included
specific opposition to Variation C1. While generally supporting Option B, WAFF
proposed several amendments to standards and specifically indicated opposition to
all Variations including Variation C6.
Wool Producers Australia (WPA) indicated support for Variation C6 and indicated
specific opposition to Variations C1 to C5. WPA supported the standards with some
amendments as proposed in Edition 1, Public Consultation Version 1.0 of the
Australian Animal Welfare Standards and Guidelines – Sheep. WPA chose to support
or reject standards on an individual basis, with suggested amendments to S5.1 and
S5.3 as currently proposed. WPA also proposed the conversion of parts of S5.1 and
entire S6.2 and S6.4 to Guidelines and the removal of S10.5 and S10.6. WPA
supported the adoption of national standards as mandatory underpinned by
unenforceable guidelines.
As reported above, submissions by industry organisations and many individual
producers varied, with many favouring Option B and opposed all the variations
except C6.
Many industry organisations made the point that their industry’s continuing support
for the standards and guidelines is dependent on successful harmonisation of State
and Territory welfare legislation.
The four Government submissions (VIC, TAS, QLD and NSW) received generally
supported the proposed national standards (Option B) with some variations.
Governments have otherwise indicated support for national standrads throughout the
development process.
Page | 16
DEPI Victoria supported only Variation C5 – it is already regulated in Victoria – and
rejected the other variations.
Tasmania supported Variation C5 and notes that it is currently a vet only procedure in
Tasmania but made no direct comment on the other variations.
The Queensland Government (DAFF) submission took issue with aspects of the RIS,
suggesting some imbalance and omissions in the benefit cost analyses, over
estimation of the costs and omission of key benefits (e.g. of training dogs and
effective control of dogs) and inadequate coverage of government costs. There is
support of all variations, except possibly C2 which was not mentioned and C6 - the
requirement for a minimum of two free palpable free joints in tails is supported.
Variation C5 is supported as in QLD Laparoscopic artificial insemination and embryo
transfer are acts of veterinary science.
NSW Department of Primary Industries supports the development of national
livestock standards and guidelines and is committed to their implementation into
regulation once they are finalised and endorsed. The issue of muzzling of working
dogs has been raised as a concern and has received careful consideration.
The SA, WA, ACT and NT Governments made no formal submissions to the public
consultation process, presumably on the grounds that they had all had opportunity to
provide comment during the drafting stage. Those in this group with significant sheep
populations expressed full support for Option B.
Page | 17
RIS options organisational position summary table
RIS Options supported
Organisation
Support Option A
NSWFF, AASMB
Support Option B (often with
qualifications)
Most governments with further
comments in text above. TGFA, AMIC,
ALRTA
SA, NSW, WA, NT Governments
Support Variation C1
QDAFF
Support Variation C2
Support Variation C3
QDAFF
Support Variation C4
QDAFF
Support Variation C5
QDAFF, Vic DEPI, Tas DPIPWE
Support Variation C6
WPA, SCA, VFF, WAFF, AgForce
Support Option C (all variations)
Animal welfare/rights groups from 17
organisations including Animals
Australia (not C6) and RSPCA Australia.
Summary of On-line Survey RIS questions
Included in the on-line survey was a number of questions raised in the Regulatory
Impact Statement. Q1-18 sought views and advice of interested parties in providing
information and data that would further assist in the assessment of the impacts (costs
and benefits) expected under the standards (option B) proposed in the RIS. The RIS
questions (1-18), seeking more specific information, were answered by an average of
38 (4%) of respondents. Little useful data was received.
The remainder of questions related to the RIS (Q19-26) sought preferences for
Options A, B and C. In reference to the total of 965 survey responses, RIS questions
19-26 (relating to Options A, B and C Variations) were answered by an average of 80
(8%) of respondents. The RIS variations questions (Q19-26) are considered in the
relevant chapters where the issue is discussed.
Below is a synopsis of the questions and the public responses to them. In general,
only a small proportion of survey participants answered the RIS related questions.
There was little confidence that the sample was representative of the population and
there was a high risk of bias. It is difficult to attach any significance to this small
Page | 18
volume of responses for some questions. A much larger number (624) felt that the
survey had given them sufficient information and allowed them to comment
adequately.
On-line survey RIS options
Q62: Which variations to the sheep welfare standards should be adopted?
Variation
% of
No. of
responses
Responses
C1 (pain relief for mulesing)
52.5%
74
C2 (mulesing under 6 months old only)
39.7%
66
C3 (ban single penning for wool
46.1%
65
C4 (ban tethering)
44.0%
62
C5 (pain relief for artificial breeding)
47.5%
67
C6 (docked tails to have at least one free
45.4%
64
None
7.1%
10
All
50.4%
71
production)
palpable joint)
Total Respondents:
141
Q63: Which option provides the best combination of costs and benefits?
Answer Choices
% of
No. of
responses
Responses
Option A
9.5%
7
Option B (the proposed standards)
18.9%
14
Option B with Variation C1 (pain relief for
36.5%
27
8.1%
6
8.1%
6
4.1%
3
mulesing)
Option B with Variation C2 (mulesing
under 6 months old only)
Option B with Variation C3 (ban single
penning for wool production)
Option B with Variation C4 (ban tethering)
Page | 19
Option B with Variation C5 (pain relief for
5.4%
4
9.5%
7
artificial breeding)
Option B with Variation C6 (docked tails to
have at least one free palpable joint)
Total
74
On-line survey questions related to the RIS process
Q72: The RIS has adequately demonstrated the need for the proposed sheep welfare
standards?
No. of responses
% Agree
% Disagree
% Neutral
89
64
17
19
Q73: The RIS has fully identified the costs of the proposed sheep welfare standards?
No. of responses
% Agree
% Disagree
% Neutral
82
38
19
43
Q74: The RIS has fully identified the benefits of the proposed sheep welfare
standards?
No. of responses
% Agree
% Disagree
% Neutral
91
49
23
28
Q75: The RIS has fully identified the range of stakeholders affected by the proposed
sheep welfare standards?
No. of responses
% Agree
% Disagree
% Neutral
86
42
24
34
Q76: Do you have any general comments relating to the RIS?
Summary of responses
There were 39 responses. Answers with any relevance to the question related to
positions on pain relief, importance of welfare and reputation of the sheep industry.
This material is covered adequately in the major submissions. Those with direct
relevance to the question should be taken into consideration in the development of
RISs for future standards and guidelines.
Page | 20
Survey questions relating to the public consultation process
The final section of the on-line survey comprised a series of questions seeking views
about the public consultation process undertaken by AHA. A summary of tabulated
responses and comments is presented below.
Q77: Where did you hear about this public consultation process?
Answer Choices
Via an organisation that I belong to.
Via an email or letter from AHA.
Via the media.
Via the internet.
Other - please provide details in comments at the
end.
Total
Responses % and No.
45.32%
286
8.24%
52
6.97%
44
34.71%
219
4.75%
30
631
Q78: Have you previously participated in any consultation process relating to sheep
welfare or the sheep welfare standards?
Answer Choices
Yes
No
Responses % and No.
11.57%
73
88.43%
Total
558
631
Q79: Which of the following best describes what area you live in?
Answer Choices
Rural
Urban
Metropolitan
Total
Responses % and No.
40.73%
257
31.70%
200
27.58%
174
631
Q80: What State/Territory do you reside in?
Page | 21
Answer Choices
QLD
NSW
VIC
TAS
ACT
SA
WA
NT
Overseas
Responses % and No.
17.43%
110
25.36%
160
22.50%
142
3.65%
23
1.90%
12
7.61%
48
14.90%
94
1.27%
8
5.39%
34
Total
631
Q81: What occupation best describes your main area of work or interest in relation to
sheep welfare?
Answer Choices
Sheep producer
Other livestock producer
Livestock industry
Livestock agent
Veterinarian
Animal welfare or animal rights organisation
Training provider
Researcher
Student
Responses % and No.
10.42%
65
1.60%
10
2.88%
18
0%
0
2.40%
15
20.35%
127
1.12%
7
3.21%
20
7.53%
47
Page | 22
Answer Choices
Responses % and No.
6.09%
38
Retiree
Home duties
Public servant
Other
6.57%
41
8.17%
51
29.65%
185
Total
624
Q82: This survey was easy to understand and complete?
No. of responses
Agree
Disagree
Neutral
624
77%
6%
17%
Q83: I believe the information provided to me as part of this survey helped me
comment on the sheep welfare standards and the RIS?
No. of responses
Agree
Disagree
Neutral
624
69%
7%
24%
Q84: This survey helped me communicate my views about the draft sheep standards
and the RIS?
No. of responses
Agree
Disagree
Neutral
624
81%
4%
15%
Q85: How would you recommend AHA consult for future Draft Australian Animal
Welfare Standards and RIS?
Answer Choices
Online questionnaire
Hard copy questionnaire
Written submission
Telephone survey
Responses % and No.
79.01%
448
3.00%
17
4.94%
28
3.00%
17
Page | 23
Answer Choices
Responses % and No.
Other - please provide further details in comments 4.76%
27
at end.
5.29%
30
Don't know
Total
567
This pattern of responses probably reflects the demographic responding to the online survey.
Q86: Do you have any general comments relating to the consultation process and how
it might be improved?
There were 221 responses to this question. A sample of 100 responses was allocated
into 9 categories. The results for the sample responses are given below.
Category
Responses %
Publicise more widely
46
Biased toward industry
1
Open to abuse by activists
2
Style, language, definitions
11
Technical or timing problems with
3
survey
2
Too complex / long
1
Provide feedback on survey outcomes
11
Good process or “No”
23
Informal (did not address the question)
100
TOTAL
The “publicise more widely” category was characterised by complaints from
respondents that they “found out about the process by accident” and that advertising
and promotion of the process was limited and failed to reach key community groups
and farmers. It included several suggestions for greater public exposure to the
consultation process, including television advertising, Facebook page, other interactive
social media forums, public meetings and even mail to individual livestock producers.
A variety of suggestions were made in the “Style, language and definitions” category;
many sought “more background”, facts to “jog the memory” and better definition of
terms used in the draft standards and guidelines for sheep and the survey questions.
Page | 24
The “Informal” category included a variety of critical and/or partisan statements
unrelated to the consultation process.
Actions
The few written submissions containing specific technical comment on statements
and assumptions in the RIS were referred to Tim Harding and Associates for
consideration in the RIS. Little new data or argument was made available during the
consultation process. The underlying methodology of the RIS will not be revised. The
RIS has not been revised in light of changes to any standard as proposed below in
this report, as these do not have a cost impact. At this time there are no additional
cost impacts acknowledged. Full details are available in the Decision RIS.
INTERNATIONAL STANDARDS
Comparisons to other countries sheep welfare standards was not identified as a
significant issue. Further country by country discussion is provided in the consultation
RIS (section1.2.3.5) and is not provided in this report. Global developments by the
World Organisation for Animal Health (OIE) and the International Organisation for
Standardization (ISO) are discussed here. The 178 countries of the World
Organisation for Animal Health (OIE) endorsed animal welfare guiding principles for
livestock at its General Assembly in 2012. These are published in the OIE
International Animal Health Code. Article 7.1.4.1
Eleven general principles for the welfare of animals in livestock production
systems:
1. Genetic selection should always take into account the health and welfare of
animals.
2. Animals chosen for introduction into new environments should be suited to the
local climate and able to adapt to local diseases, parasites and nutrition.
3. The physical environment, including the substrate (walking surface, resting
surface, etc.), should be suited to the species so as to minimise risk of injury and
transmission of diseases or parasites to animals.
4. The physical environment should allow comfortable resting, safe and comfortable
movement including normal postural changes, and the opportunity to perform types
of natural behaviour that animals are motivated to perform.
5. Social grouping of animals should be managed to allow positive social behaviour
and minimise injury, distress and chronic fear.
1
http://www.oie.int/index.php?id=169&L=0&htmfile=chapitre_1.7.1.htm
Page | 25
6. For housed animals, air quality, temperature and humidity should support good
animal health and not be aversive. Where extreme conditions occur, animals should
not be prevented from using their natural methods of thermo-regulation.
7. Animals should have access to sufficient feed and water, suited to the animals'
age and needs, to maintain normal health and productivity and to prevent prolonged
hunger, thirst, malnutrition or dehydration.
8. Diseases and parasites should be prevented and controlled as much as possible
through good management practices. Animals with serious health problems should
be isolated and treated promptly or killed humanely if treatment is not feasible or
recovery is unlikely.
9. Where painful procedures cannot be avoided, the resulting pain should be
managed to the extent that available methods allow.
10. The handling of animals should foster a positive relationship between humans
and animals and should not cause injury, panic, lasting fear or avoidable stress.
11. Owners and handlers should have sufficient skill and knowledge to ensure that
animals are treated in accordance with these principles.
Professor David Fraser and others have developed a scientific paper that informed
these OIE general principles. It was published in the Veterinary Journal2 in June
2013. The Australian Animal Welfare Standards and Guidelines for Sheep are
consistent with these principles.
The International Wool Textile Organisation (IWTO) best practice guide Guidelines
for Wool Sheep Welfare was developed in 2013. The objective of this guide is to
clearly define and widely promote animal welfare practices in wool production,
relevant to the wide diversity of production environments around the globe.
While specifically relevant to the global wool sheep production industry, these good
welfare practices are closely aligned with the OIE Terrestrial Animal Health Code.
http://www.iwto.org/uploaded/publications/WEB_IWTO_Sheep_Welfare_Guidelines_
Web.pdf
General issues
General issues including scope of the standards, language and construction of
standards, definitions, consistency in legislation, monitoring and enforcement, of the
standards, independence and credibility of the standards development process,
decision making, post consultation process and future communication have been
2
David Fraser, Ian J.H. Duncan, Sandra A. Edwards, Temple Grandin, Neville G. Gregory, Vincent Guyonnet, Paul
H. Hemsworth, Stella M. Huertas, Juliana M. Huzzey, David J. Mellor, Joy A. Mench, Marek Špinka, Rebecca
Whay. General Principles for the welfare of animals in production systems: The underlying science and its
application. The Veterinary Journal 198 (2013) 19–27.
Page | 26
discussed comprehensively during the development process. Some are outside the
scope of this particular development process but may be relevant to the planned
revision of the Standards and Guidelines Development Business Plan for all future
livestock welfare projects.
SCOPE – RELATIONSHIP BETWEEN THE STANDARDS
AND GUIDELINES
The standards and guidelines document is a dual purpose document. It is intended to
provide a basis for developing laws and also a basis for industry quality assurance
programs. The intended wide readership requires that a plain English approach be
used. Various concerns about the role of the guidelines are acknowledged.
The standards are the animal welfare requirements that will become law. Standards
use the word ‘must’.
The guidelines are the recommended practices to achieve desirable animal welfare
outcomes. Guidelines use the word ‘should’. Noncompliance with one or more
guidelines will not constitute an offence under law.
The guidelines are not written to describe how to achieve these standards, instead
they describe a better welfare position than the standard. The overall philosophy is
that the private sector has the prime responsibility for livestock welfare and that this
document will provide a basis for determining acceptable practices with the
guidelines pointing towards best practice. This development process has created an
opportunity for all three sectors of stakeholders to work together to develop or refine
agreed industry guidelines on a regional or national basis and to focus research
investment on contentious issues.
Prosecution against the regulations is the option of last resort. Industries are
expected to have shared ownership of the standards and guidelines and to champion
their uptake through education and engagement and to foster a culture of best
practice and continuous improvement.
The position taken by PIMC 15, in May 2009, is that guidelines, regardless of their
purpose in existing Codes and the new standards and guidelines documents, will not
be regulated.
In particular agreement was reached that:
“All future revisions of Model Codes and ‘Australian Standards and Guidelines’
documents must provide a number of:
a) clear essential requirements (‘standards’) for animal welfare that can be
verified and are transferable into legislation for effective regulation, and
Page | 27
b) guidelines, to be produced concurrently with the standards but not enforced in
legislation, to be considered by industry for incorporation into national industry
QA along with the standards.
From the interpretation section of the introduction in the proposed Australian Animal
Welfare Standards and Guidelines for Sheep:

Standards — the animal welfare requirements designated in this document
(i.e. the requirements that must be met under law for livestock welfare purposes)
The standards are intended to be clear, essential and verifiable statements.
However, not all issues are able to be well defined by scientific research or are
able to be quantified. Science cannot always provide an objective or precise
assessment of an animal’s welfare and, consequently, where appropriate science
is not available, the standards reflect a value judgement that has to be made for
some circumstances. Standards use the word ‘must’. They are presented in a box
and are numbered with the prefix ‘S’. The use of hyperlinks in the standards
indicates a defined term.

Guidelines — the recommended practices to achieve desirable animal welfare
outcomes. Guidelines use the word ‘should’ and complement the standards.
Noncompliance with one or more guidelines will not constitute an offence under
law.
Use of defence clauses is not considered to be an advantage for the regulatory
system and has not been used. It is acknowledged that suggestions for restructure of
the standards and guidelines have been made but it is not intended to make any
structural change at this time.
The standards do not relate to transport or live exports Recommendations in relation
to land transport, ships, aircraft or the live export process are not addressed in this
report.
General standards – language and construction
The dual purpose nature of the draft standards and guidelines for sheep and the
plain English approach used means that the document has a broader extension
value to the sheep industry and community than just the creation of regulations. The
draft standards and guidelines for sheep contains standards that are general and
outcomes based or are detailed and prescriptive, or a mixture of the two types. The
value of the general standards has been agreed by the majority of the reference
group.
General standards are written because the complexity of biological systems means
that it is impossible to develop standards which anticipate all circumstances that
could have adverse outcomes or account for regional or environmental differences.
The use of general standards has been minimised as it is recognised that it creates a
need for further explanation or interpretation.
Page | 28
The use of general, non-prescriptive standards creates a dilemma for regulators and
industry. Animal welfare activists believe that this approaches promotes the retention
of current, unacceptable practices. Specifically, there are concerns about the use of
common usage terms such as ‘effective, (used once) reasonable, at the first
reasonable opportunity (used twice), appropriate, and adequate (used once), which
have not been and are not intended to be, specifically defined. These views were
expressed and taken into account during the drafting process and in general the
usage of general terms has been reduced.
The term ‘reasonable’ is used nine times and ‘appropriate’ used three times in
standards. It is acknowledged in law that the word ‘reasonable’ has the prima facie
meaning of ‘reasonable’ in regards of those existing circumstances of which the
defendant, called upon to act reasonably, knows or ought to know.
In the introduction of the draft standards and guidelines for sheep a ‘reasonable
action(s)’ is characterised as ‘those actions regarded as reasonable to be done by an
experienced person in the circumstances to address a problem, as determined by
accepted practice and by other similarly experienced people. Use of the term has
been agreed by the reference group to reflect the complexity of circumstances
covered by the standards. It is acknowledged that the clause is open to interpretation
and creates some uncertainty.
Usage in relation to ‘at the first reasonable opportunity’ has been criticised for
implying a lack of timeliness or urgency, with alternatives to the phrase suggested
such as ‘promptly’ or ‘immediately’. These options have been considered by the
reference group and rejected in favour of the more flexible phrase to allow sheep
owners to optimally prioritise their responsibilities.
The use of the phrase; “to minimise risk to the welfare of sheep” in the objectives
statements of the draft standards and guidelines for sheep points towards a common
understanding of what is ‘reasonable’ in sheep husbandry in those areas where a
complex interaction of factors make it difficult to create an acceptable prescriptive
rule for the country. The expectation of what is ‘reasonable’ may be different between
the sheep industries and the community. This reflects the widening knowledge gap
between urban populations and livestock production systems. This conundrum may
require prosecution test cases, education, and over time community expectations
may change.
Governments support the notion and value of general standards and there has been
a conscious effort to develop the best option for clear, essential and verifiable
standards where possible. Of the 38 standards proposed in the draft, approximately
17 standards are general or have non-prescriptive elements.
An economy of words is pursued in the standards with minimal descriptive terms. The
preferred use of terms has been built on the basis of past legal workshops, standards
development and implementations. Notably, The Australian Animal Welfare
Page | 29
Standards and Guidelines for the Land Transport of Livestock3. The lack of
prescription and resulting inefficiency is acknowledged but this is in due recognition
of the vast range of mitigating factors that may impact on welfare management in
certain situations, for example during a natural disaster.
Use of defence clauses is not considered to be an advantage for the regulatory
system and has not been used in the document. Revisions to specific standards are
examined on a case by case basis later in this report.
Definitions
As stated above, the standards and guidelines document is a dual purpose
document. The intended wide readership requires that a plain English approach be
used and common use definitions are preferred. The definitions proposed have been
carefully reviewed as they are an integral part of the draft standards and guidelines
for sheep and are important to achieve consistent implementation of the standards.
Comprehensive debate has occurred on the key issue of competency and its
definition. Many submissions referred to the terms “knowledge, experience and
skills”, which are used throughout the draft standards and guidelines for sheep to
describe competency requirements in relation to both general animal husbandry and
more specific invasive procedures. The tendered view is that for such standards to be
effective and verifiable, a system of assessment (and/or a record of training or
accreditation) must be available to prove or disprove compliance. Where training and
certification is required for a husbandry practice, this is specified.
Revisions to specific standards are examined on a case by case basis later in this
report.
Consistency in legislation, monitoring and enforcement
The improvement of the regulatory system is only part of the justification for
developing welfare standards. The achievement of harmonisation between
jurisdictions regulatory systems is a major benefit of the standards development
process. It is now accepted by a majority of parties that while full consistency is the
ultimate goal, and ongoing reviews will continue to move that way, jurisdictional
sovereign rights will remain a basis for minor variations prescribing different
standards, judged to be appropriate for local conditions. These differences will occur
despite the limitations of the science-base and enforceability of some standards.
Jurisdictions have stated previously for the RIS that no new resources will be made
available for compliance and enforcement activities. Implementation is important but
it is not an issue for the development of the standards. The RIS is a major test of the
efficiency of new regulations and the value to the system. It is believed that there is
industry and government commitment to the implementation of welfare standards.
http://www.animalwelfarestandards.net.au/land-transport/
Page | 30
Public submissions expressing uncertainty and lack of confidence about the capacity
and commitment of governments to promote, monitor and enforce regulated
standards did not include any reference to the role of industry organisations in these
activities or the development of industry quality assurance programs, which have
been promoted by some industry groups as the preferred “self-regulatory”
compliance strategy.
Consistency of enforcement programs is an important but separate issue from
settling the standards and guidelines themselves, and from the role of industry
groups in promotion and monitoring of compliance.
Independence and credibility of the standards development process
AHA works to protect and improve animal health and welfare within Australia. AHA is
a not-for-profit public company established by the Australian, state and territory
governments and major national livestock industry organisations. AHA’s role is to
facilitate improvements in Australia’s animal health policy and practice in partnership
with the livestock industries, governments and other stakeholders.
Under the AAWS, AHA manages the development of Australian Animal Welfare
Standards and Guidelines for Sheep under an agreed development business plan
established in 2005 and reconfirmed by government in 2009.
The vision is to establish national livestock welfare standards that reflect
contemporary scientific knowledge, competent animal husbandry and mainstream
community expectations, and that these standards are maintained and enforced in a
consistent, cost-effective manner.
The fundamental components and workings of the development process are
described in the introduction of the draft standards and guidelines document and in
the agreed development business plan, available at the consultation website
www.animalwelfarestandards.net.au.
An independent Chair oversees the two committees involved in development. The
writing and reference groups have an agreed terms of reference, new membership,
communication and record keeping policies for the project. The preparation of the
standards represented a significant investment of time and effort by all parties,
especially members of the writing and reference groups.
The sheep writing group is responsible for drafting the standards and guidelines for
sheep. It is comprised of representatives from state and territory governments
through Animal Welfare Committee (AWC), Sheepmeat Council of Australia (SCA),
WoolProducers Australia (WPA), CSIRO and the Department of Agriculture. The
group is led by an independent Chair and supported by AHA. The RSPCA national
body is specifically consulted at certain times for more complete animal welfare
ethical considerations.
The sheep reference group is comprised of representatives from all aspects of sheep
care and management. Sheep reference group meetings are held to review the
Page | 31
standards and guidelines draft and to provide further guidance - a public consultation
period is part of the process. The group is led by an independent Chair and
supported by AHA.
The role of AHA is to:
1. Manage the overall process for the development of standards and guidelines
according to the revised Standards and Guidelines Development Plan and under
the direction of the writing group funding members and the reference group for
each project.
2. Provide support to the Chair and provide leadership to facilitate solutions for
animal welfare issues.
3. Recruit and manage outside consultants for key tasks, specifically; literature
review, RIS, public consultation and editing.
4. Provide project support.
5. Ensure that final reports satisfy stakeholder requirements.
The overall outcome is to maintain a high level of consensus in decision making and
transparency in recording any revised position. The project groups will disband with
the passage of the documents to governments for consideration for endorsement in
2014
The initial decision in 2008 to develop the sheep welfare standards was a shared
decision between all governments and the sheep industry peak bodies, Sheepmeat
Council and Wool Producers Australia. It is acknowledged that the slow pace of
development has in some cases contributed to mistrust over lack of apparent
communication. Restricted resources for communication has meant that some
participants may not have been adequately informed, and that the demands of some
stakeholders cannot not be met. Communication has relied on key industry,
community, service provider, and government stakeholders, promoting, and passing
information on, the process to their networks of contacts. A project meeting history is
available at the website: http://www.animalwelfarestandards.net.au/sheep/
At the AHA-Government livestock Welfare Relationships Workshop on 8 and 9 March
2011, commitment was given to reviewing the Australian Animal Welfare Standards
and Guidelines Development Business Plan at the completion of the sheep and cattle
welfare projects. The concerns of welfare organisations, particularly in relation to the
consultation process and resources were acknowledged. Subsequently, the
Department of Agriculture Fisheries and Forestry (DAFF, now Department of
Agriculture) commissioned a review of the standards and guidelines development
process by the firm, Price Waterhouse Coopers. The report in July 2013 (available on
the departments website) recommended fine tuning of various elements of the
process which is acknowledged to be relevant for future standards development
projects and less relevant for this project which is now in the final stages.
Page | 32
The conclusion of the revision of the sheep welfare standards will be conducted
according to the business plan described at the website
http://www.animalwelfarestandards.net.au/
Finalisation with a recommendation to Ministers is planned for May 2014.
Decision making
Ultimately the revised standards and guidelines and the revised RIS are
recommended to Ministers via the AWC, for consideration for endorsement.
The AWC is comprised of senior government representatives within departments of
Agriculture who have animal welfare responsibilities. The AWC reports to the heads
of Department (formally Primary Industries Standing Committee), which in turn
reports to Ministers with responsibility for Primary Industry matters.
The Standing Council on Primary Industries (SCoPI) has considered priority issues of
national significance affecting Australia’s primary production sectors which require a
sustained and collaborative effort across jurisdictions and address key areas of
shared Commonwealth, state and territory responsibility and funding for Australia’s
primary production sectors.
SCoPI has developed and implemented policies and strategies for achieving agreed
national approaches to biosecurity, productivity and sustainability of primary
industries (including fisheries and forestry industries) and food security. It
encouraged greater collaboration and promotes continuous improvement in the
investment of research and development resources nationally.
Post consultation process
Following compilation of submissions, AHA prepared documents for consideration
firstly by the writing group and then the reference group consistent with the
development business plan. Whilst the focus is primarily on the standards, all matters
are considered. Further details on participants and process are available at the below
website:
http://www.animalwelfarestandards.net.au/
The categorisation and handling of issues identified in the public consultation was:
1. Irrelevant, not understood or factually incorrect material – no further action,
explanation may be recorded. Where there has been a simple error of fact or
interpretation of the proposed documents – this is not mentioned or corrected in
this report. Communications with the stakeholder may have occurred to clarify
issues of concern.
2. Minor correction or clarification – changes made and compiled for reference group
consideration, including all guideline changes proposed.
Page | 33
3. Significant specific issue but no new solutions proposed in the context of previous
reference group discussions – no further action but an explanation provided in the
body of the consultation response report which may be further discussed.
4. Significant specific issue described, to be further considered by the reference
group or subject to further collaborative working group process.
There were many suggestions for guidelines to become standards and vice versa. If
the suggestions were accepted, the resultant action was to either redraft or delete the
guideline or standard. Appropriate recommendations have been made for
subsequent actions. Changes to standards and definitions with legal and/or cost
implications will be examined under the RIS process.
As previously mentioned the four main decision-making principles used for standards
are that they are:
•
Desirable for livestock welfare
•
Feasible for industry and government to implement
•
Important for the livestock-welfare regulatory framework and,
•
Will achieve the intended outcome for livestock welfare.
To expand on these major points in relation to any revision:
•
Desirable for livestock welfare - the proposal leads to a worthwhile
improvement in the welfare of sheep including that it is based on scientific
research that has not yet been recognised and evaluated by the reference
group. The specific proposal is proportionate to the magnitude of any proven
welfare issue. Work health and safety considerations take precedence over
sheep welfare, particularly in an emergency situation. There is a legal basis for
this and also in a practical sense an injured person is not able to further care
for the sheep.
•
Feasible for industry and government to implement. The proposal is able to be
implemented by industry and government with reasonable adjustment and
cost. The RIS is a useful test of cost considerations.
•
Important for the livestock-welfare regulatory framework. Preference is given
to standards and guidelines that are prescriptive and are able to be measured
or audited. Alignment with existing animal welfare concepts expressed in
existing laws and the standards and guidelines proposal. The specific proposal
has not been previously rejected by the reference group in the context of the
current standards and guidelines framework and fills a gap in the current draft
standards and guidelines for sheep proposal. This aspect also includes the
number and variety of responses that indicate shared concerns and the depth
of reasoning behind these concerns and the proposed solutions.
Page | 34
•
Will achieve the intended outcome for livestock welfare. The proposal does not
contradict or confuse other laws or proposed standards and guidelines or does
not result in an action that has negative consequences for sheep.
The list does not infer emphasis in the logic that may be applied and in most cases
there were multiple reasons for a decision. Only the main reason for a
recommendation in this draft report is cited. In many cases several of the above
points were relevant.
Submissions from animal welfare/rights organisations and from many individuals
apparently supporting them, disputed the introductory statement that the standards
“reflect available scientific knowledge, current practice and community expectations”.
Claims that the standards are out of touch with community values and expectations
and do not lead to industry change in current practice, are difficult to substantiate
particularly with the evidence provided. These views were also expressed and taken
into account during the drafting process. Further revisions to specific standards are
examined on a case by case basis later in this report.
Future communication and extension
There is a huge need for tailored consultation and communication with relevant
industry sectors once the standards are endorsed by state and territory governments.
This consultation should include a detailed discussion on the implementation of
standards into state or territory legislation. There will need to be consideration of how
successful sustained, long term communication might be achieved by stakeholders.
In part this will be assisted by the AAWS which has recently developed a
communication strategy for the sheep welfare standards.
The Communication Strategy was supported by the AAWS and its development was
managed by Meat and Livestock Australia on behalf of the AAWS Livestock and
Production Animals Working Group. One of the two documents produced is written
specifically for the final launch of the cattle and sheep standards and guidelines and
the other is a more generic 'template' for other standards and guidelines as they are
developed and released in the future.
Page | 35
SPECIFIC ISSUES BY CHAPTER
Chapter 1 Responsibilities
S1.1 A person must take reasonable actions to ensure the welfare of sheep under
their care.
The following changes to standards were suggested:
I/d
Submitted Suggested Revision
by
S1.1
Various
Open to interpretation (RSPCA, ALQ¹, WSPA²,
other welfare/rights groups) - Impossible to audit
(Sentient) – do not accept “reasonable actions”
Definition of “reasonable actions” is inadequate
- should not refer to “accepted practice” or
“experienced person in the circumstances” (many
submissions)
WSPA – S1.1 is not verifiable unless “reasonable
actions” and “welfare outcomes” are defined
RSPCA, WSPA, ALQ, Sentient – all want some or
all elements of G1.1 incorporated into S1.1
Reword to require a person..... to have a duty of
care to ensure the welfare of those sheep” – which
includes reasonable actions in G1.1 (Vic DEPI)
ALQ -...”this standard should either require
‘competency’ in a person’s dealing with sheep and
competency could be achieved by an
accredited national training scheme...”
Recommendation /
Action Taken / Revised
Content
No further action was
agreed
No change recommended by the writing group or the reference group. It is
acknowledged that this is a general standard that is difficult to enforce but has an
important message for the acceptable management of sheep. The value of the
general standards has been agreed by the majority of the reference group in
previous meetings. The use of general standards has been minimised as it is
recognised that it creates a need for further explanation or interpretation.
The term ‘reasonable’ is used nine times and appropriate used three times in
standards. It is acknowledged in law that the word ‘reasonable’ has the prima facie
meaning of ‘reasonable’ in regards of those existing circumstances of which the
defendant, called upon to act reasonably, knows or ought to know.
In the introduction a ‘reasonable action(s)’ is characterised as ‘those actions
regarded as reasonable to be done by an experienced person in the circumstances
to address a problem, as determined by accepted practice and by other similarly
experienced people. It is not intended that all reasonable actions are described in this
Page | 36
document’. Use of the term has been agreed by the reference group to reflect the
complexity of circumstances covered by the standards. It is acknowledged that the
clause is open to interpretation and creates uncertainty.
In considering the need for further standards, the project groups assessed four main
decision-making principles for standards. That the proposal is:
•
Desirable for livestock welfare
•
Feasible for industry and government to implement
•
Important for the livestock-welfare regulatory framework and,
•
Will achieve the intended outcome for livestock welfare.
The following to guidelines were suggested:
I/d
Submitt
ed by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
G1.1
Hides
(Vet) in
relation
to cattle
Should include new dot point knowledge of
local patterns of disease, disease prevention
and use of low stress stock handling
techniques.
AGREED CHANGE
G1.1 Elements of responsibility for sheep
management should include:
 understanding the standards and guidelines for
sheep welfare
 obtaining knowledge of relevant animal welfare
laws
 understanding sheep behaviour and use of low
stress stock handling techniques
 planning and undertaking actions for the
enterprise to meet the welfare standards and
address contingencies that may arise
 assessing the quantity, quality and continuity of
feed and water supply
 handling to minimise stress, and using handling
aids, facilities and other equipment
appropriately
 undertaking hygienic husbandry procedures in
a manner that minimises the risks to sheep
welfare
 understanding and following chemical and drug
treatment instructions for sheep
WG agreed – additional
dot point - knowledge of
local patterns of disease,
disease prevention and
use of low stress stock
handling techniques to
remain consistent with
cattle.
SRG supported and
agreed the changed
placement of the new dot
point.
Page | 37
I/d
Submitt
ed by
Suggested Revision




G1.2
Vic DEPI
in
relation
to cattle
Recommendation /
Action Taken / Revised
Content
identifying distressed, weak, injured or
diseased sheep, and taking appropriate action
knowledge of local patterns of disease, disease
prevention and use of low stress stock handling
techniques
maintaining appropriate records
humanely killing sheep by appropriate methods,
or seeking the assistance of someone who is
capable and equipped to kill them humanely.
Suggest change to “understood by all parties
involved”.
Previous - G1.2 Agistment responsibilities should
be communicated, documented and clearly
understood by both parties.
AGREED CHANGE
G1.2 Agistment responsibilities should be
communicated, documented, and clearly
understood by allboth parties involved.
WG agreed to the
suggested change to
remain consistent with
cattle.
SRG supported.
Two revisions to the guidelines have been recommended in this chapter in response
to the submissions.
Page | 38
Chapter 2 Feed and Water
S2.1 A person in charge must ensure sheep have reasonable access to adequate
and appropriate feed and water.
The following changes to standards were suggested:
I/d
Submitted Suggested Revision
by
S2.1
Various
New
Various
Standard
Recommendation /
Action Taken / Revised
Content
Access to water at all times (i.e. daily) RSPCA, AA¹, WSPA, ALQ, PAM², Sentient,
Saklani and followers (most content identical to
RSPCA), Animals Australia, ALC³, other lawyer
groups, several individual submissions, General
public.
Daily access to water should be a standard
except for assembling for yarding and/or
transport (Vic DEPI).
Should include a maximum time off water
(TOW) for on-farm consistent with the times
allowed during transport (Vic DEPI).
PETA suggests replace “reasonable” with
“sufficient to meet all welfare needs, as judged
by clear, verifiable factors”.
“Reasonable access” implies access should
not be assured or guaranteed but merely
“reasonable”.
Re-word to make it an offence to fail to provide
adequate and appropriate feed and water,
subject to the defence of no failure to take
reasonable care (LSSAⁿ, L MacLaren MLC)
No Further Action. See
text in chapter one and in
general issues for
discussion of ‘reasonable
actions’.
Mandate a minimum condition score of 1.5
(RSPCA SA, WSPA) – between 2.5 and 5 (PAM)
– minimum score 1.3 (AVA) – 1.5 (Evans).
No further action was
agreed - MLA have
recently released Body
Condition Score (BCS)
guide. A BCS standard
was considered to be too
prescriptive for a national
approach.
LSSA models its
suggestions on SA
Animal Welfare Act,
avoiding ambiguity of
terms including
“reasonable”. It is alleged
that “reasonable care” is
an easier concept in the
courts. This view was not
upheld.
TOW – standard agreed
not consistent with the
draft standards and
guidelines for sheep
approach to date.
Transport is a more
stressful situation that
requires prescriptive
limits.
Page | 39
I/d
Submitted Suggested Revision
by
New
Vic DEPI
Standard
A new Standard should specify a minimum
“mob average” body condition score for each
class of sheep (Vic DEPI)
Recommendation /
Action Taken / Revised
Content
No Further Action Roughage question
considered covered by
‘adequate and
appropriate”.
See chapter one for discussion on general standards and ‘reasonable’.
The following changes to guidelines were suggested:
I/d
Submitted
by
Suggested Revision
Recommendation /
Action Taken /
Revised Content
Objective
Evans
Sheep have access to - insert ‘appropriate’
feed and water to minimize the risk to their
welfare insert ‘prevent hunger and thirst, and
to meet physiological requirements’.
No further action was
agreed
G2.1
Various
Convert to a Standard to replace S2.1
(PETA, WSPA, Sentient, Evans)
Reduce time off to 36 hours (WSPA) –
DAFF to justify 48 hours.
Deprivation of feed or water for more than
48 hours is prima facie evidence of cruelty
unless it can be demonstrated that it was
unavoidable in the circumstances
(MacLaren)
Deprivation for 48 hours is excessive for
lambs, lactating or pregnant ewes and any
sheep under excessively hot conditions
(Sentient)
G2.1 Sheep should have access to feed and
water daily, except where reasonable
management practices, such as shearing,
preparation for sale, transport, slaughter and
drenching, result in a longer period of water
deprivation, to a maximum of 48 hours. Feed
and water deprivation exceeding 48 hours
should be avoided.
No further action was
agreed
G2.2
WSPA
Upgrade to a standard
G2.2 If sufficient feed and water cannot be
provided to sheep, options that should be
considered are to relocate, agist, sell or
humanely kill the sheep before sheep
welfare is adversely affected.
No further action was
agreed
Page | 40
I/d
Submitted
by
Suggested Revision
Recommendation /
Action Taken /
Revised Content
G2.5
Vic DEPI
Upgrade to a standard add “to ensure
adequate supply”.
G2.5 Regular assessment should be made
of the needs of the sheep in relation to the
quantity and quality of feed and water.
No further action was
agreed
G2.6
MacLaren
Upgrade to a Standard
No further action was
G2.6 Self feeders and watering points should agreed
be checked regularly and maintained.
G2.7
PAM
Delete “or managed”.
G2.7 Access by sheep to contaminated and
spoilt feed, toxic plants and harmful
substances should be managed or avoided if
possible.
No further action was
agreed
The sheep writing group and the sheep reference group agreed to no changes in
chapter two.
Page | 41
Chapter 3 Risk Management
S3.1 A person in charge must take reasonable actions to ensure the welfare of
sheep from threats, including *extremes of weather*, *drought*, fires, floods,
disease, injury and predation.
S3.2 A person in charge must ensure the *inspection* of sheep at intervals, and at
a level appropriate to the production system and the risks to the welfare of
sheep.
S3.3 A person in charge must ensure appropriate treatment for sick, injured or
diseased sheep at the first reasonable opportunity.
The following changes to standards were suggested:
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken / Revised
Content
S3.1
Various
Replace “reasonable” with “appropriate”
(Evans)
Not strong enough – Access to shelter must be
available at all times (RSPCA, WSPA, AA, ALQ,
PAM, PETA, Saklani, Lawyer groups and others)
Replace “ensure the welfare of” with “protect”
(MacLaren)
No further action was
agreed G3.6 exists to
provide guidance. Shelter
presents challenges in
most production systems.
S3.2
Various
Inadequate for enforcement – needs more detail
to define limits and contingencies (PETA,
MacLaren)
No further action was
agreed
Change to At least every two days (AA, Edgar’s
Mission)
Should be a guideline (SCA¹).
S3.3
Various
LSSA – concerns with “at the first reasonable
opportunity” – undefined and creates strong
defence.
Remove “ at the first reasonable opportunity”
(Evans)
Insert “prompt and” before “appropriate” and
replace “reasonable” with “available” (AA).
No further action was
agreed
It is acknowledged in law that the word ‘reasonable’ has the prima facie meaning of
‘reasonable’ in regards of those existing circumstances of which the defendant, called
upon to act reasonably, knows or ought to know.
In the introduction a ‘reasonable action(s)’ is characterised as ‘those actions
regarded as reasonable to be done by an experienced person in the circumstances
Page | 42
to address a problem, as determined by accepted practice and by other similarly
experienced people. It is not intended that all reasonable actions are described in this
document’. Use of the term has been agreed by the reference group to reflect the
complexity of circumstances covered by the standards. It is acknowledged that the
clause is open to interpretation and creates uncertainty.
Usage in relation to ‘at the first reasonable opportunity’ has been criticised for
implying a lack of timeliness or urgency, with alternatives to the phrase suggested
such as ‘promptly’ or ‘immediately’. These options have been considered by the
reference group and rejected in favour of the more flexible phrase to allow sheep
owners to optimally prioritise their responsibilities.
The use of the phrase; “to minimise risk to the welfare of sheep” in the objectives
statements points towards a common understanding of what is ‘reasonable’ in sheep
husbandry in those areas where a complex interaction of factors make it difficult to
create an acceptable prescriptive rule for the country. It is this difficulty in developing
a single national standard for say, inspection of sheep, that is relevant and fairly
applicable for all sheep management circumstances, that precludes the further
development of a national standard.
The following changes to guidelines were suggested:
I/d
Submitted
by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
Numero
us
Various
G3.1, 3.3, 3.5, 3.7, 3.10, 3.12, 3.14 – convert to
Standards (RSPCA SA, PAM, Sentient) – add
G3.6 (WSPA, Sentient)
G3.5 - 9 (Evans), G3.2 include in S3.2 (Sentient),
G3.7, G3.9 (PETA), G2.12, G3.13, G3.16
(MacLaren), G3.9, G3.16 (Sentient), Convert G3.7
and G3.14 to standards (Vic DEPI, Evans) Convert G3.14 to a standard (LSSA), G3.10, and
G3.12 should be standards (Evans).
No further action was
agreed
G3.3
Vic DEPI,
Evans
Part of G3.3 must be a Standard – amend to “A
person observing sheep caught in a structure or
bogged must ensure appropriate action is
undertaken at the first reasonable opportunity to
alleviate the welfare problem”.
Add without delay
G3.3 Sheep that appear to be isolated from the
flock, caught in structures or bogged should be
inspected immediately and appropriate action taken
without delay.
No further action was
agreed
Convert first part of G3.6 to a Standard
G3.6 Sheep and lambs should be provided with
adequate shelter. In the absence of natural
No further action was
agreed
G3.6
Vic DEPI,
Evans, AA
Agreed delete
“immediately” and add
“without delay” to be
consistent with wording of
guidelines.
SRG supported.
Page | 43
I/d
Submitted
by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
protection, consideration should be given to the
provision of shade, windbreaks or sheds.
G3.8
Dr A R
Butler
Needs better emphasis (or re-wording as a
Standard):
“Shearing itself is one of the most, if not the most
stressful husbandry practice that we do to sheep.
....It is the event to which sheep develop the
greatest behavioural aversion. For sheep, many
adverse events may follow shearing, including
hypocalcaemia, hypoglycaemia, plant poisoning
(through hungry sheep consuming plants in
quantities not normally consumed), severe blood
loss, fractures, severed tendons, backline dermal
necrosis and severe infections including CLA. The
risk of hypothermia due to cold wet windy weather
following shearing is well known”.
G3.8 Protection for sheep around shearing may
include:
 postponing shearing
 using snow combs
 providing shelter
 providing wind breaks
 providing additional feed.
No further action was
agreed – acknowledge
shearing is stressful
however it’s over in
15mins. Creating aversion.
G3.16
Windsor
Reference to clips as better technology is risky
given the results.
No further action was
agreed
G3.16 Where flystrike is a risk, preventive
techniques that should be considered are:

selecting replacement sheep with greater
genetic resistance to flystrike

culling sheep with high wrinkle scores

culling previously struck sheep

tactical crutching/shearing during high
prevalence periods

strategic chemical use

using an effective flock worm control program
and/or grazing management to prevent
scouring

selecting replacement sheep with correct tail
length and/or breech modification

tail docking lambs
Page | 44
I/d
Submitted
by
Suggested Revision

using clips and other appropriate new
technologies

mulesing lambs.
Recommendation /
Action Taken / Revised
Content
Considerable discussion occurred at the reference group meeting on the topic of
‘shelter’. No changes were made but it is acknowledged as an important issue for
sheep and one for which it is difficult to develop a meaningful and fair statement for
regulation. One revision to the guidelines have been recommended by the writing
group in this chapter in response to the submissions.
Page | 45
Chapter 4 Facilities and Equipment
S4.1 A person in charge must take reasonable actions in the *construction*,
maintenance and operation of *facilities* and equipment to ensure the
welfare of sheep.
The following changes to standards were suggested:
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken / Revised
Content
S4.1
Various
Definition of construction
and facilities - use plain
English meaning.
Open to interpretation – RSPCA , ALQ, WSPA,
AA et al - Don’t accept “reasonable actions”
WSPA seeks to replace “take reasonable
actions” with “ensure”
“Facilities” must include shade (AA).
New
Sentient
Standard
Mandate training “in the appropriate use of
facilities and equipment”.
No further action was
agreed
No further action was
agreed
See chapter one discussion. No change the standards recommended.
The following changes to guidelines were suggested:
I/d
Submitted by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
Numerous
Various
All Guidelines (G4.1-G4.5) should be
converted to Standards (RSPCA,
Sentient)
No further action was
agreed
G4.1 should be a Standard (WSPA)
G4.2 should be a Standard (Evans,
RSPCA SA, ALQ, PAM)
Don’t need G4.2 if G3.6-7 are standards
(WSPA)
G4.3 and G4.4 should also be standards
(Evans, RSPCA SA, PAM).
G4.4
Vic DEPI
Upgrade to a Standard – otherwise in
conflict with S4.1 and LTS SA3.1 (iv).
G4.4 Facilities should be free from
protrusions and obstacles that may cause
injury.
G4.4. No further action
was agreed is a higher
recommendation than
S4.1 and the change from
‘may’ will mean a lower
recommendation.
Page | 46
I/d
Submitted by
Suggested Revision
SA3.1 A person in charge must ensure
that the vehicles and livestock handling
facilities are constructed, maintained and
operated in a way that minimises risk to
the welfare of livestock.
Vehicles and facilities must:
i) be appropriate to contain the species;
and
ii) have effective airflow; and
iii) have flooring that minimises the
likelihood of injury or of livestock
slipping or falling; and
iv) be free from internal protrusions and
other objects that could cause injury; and
Recommendation /
Action Taken / Revised
Content
Problem with LTS SA 3.1
iv – ‘could’ should be ‘will’
is a contextual issue that
should be addressed in a
future revision of the LTS.
It refers for the potential of
an object to cause injury to
be mitigated, as opposed
to dealing with a
recognised hazard. It was
stated that the recognition
of a higher degree of risk
in transport situations is
appropriate.
v) have sufficient vertical clearance for
livestock to minimise the risk of injury.
The sheep writing group and the sheep reference group agreed to no changes in
chapter four.
Page | 47
Chapter 5 Handling and Husbandry
S5.1
A person must handle sheep in a reasonable manner.
S5.1b A person handling sheep must not and must not:
1) *lift* sheep off
the ground by only one leg, or by the head, ears, horns, neck, tail
or wool, unless in an *emergency*; or
2) throw or drop sheep, except to land on its feet from a height less than 1.5one
metres; or
3) strike sheep in an unreasonable manner, punch or kick; or
4) drag sheep that are not standing by only one leg, except in an emergency to
allow safe handling, *lifting*, treatment or humane killing; or
5) drag sheep by only the ears, or tail; or wool; or
6) drag sheep by mechanical means, except in an *emergency*, for the minimum
distance to allow safe handling, *lifting*, treatment or humane killing.
S5.2
A person in charge of a dog that habitually bites sheep must ensure the dog
is muzzled the dog while working sheep.
S5.3
A person in charge must ensure a sheep is shorn before the wool length is
greater than twice the average annual growth for that breed. reaches
250mm in length.
S5.4
A person must consider the welfare of sheep when using an electric
prodder, and must not use it:
1) on genital, anal, or udder or facial areas of sheep; or
1b) on facial areas, unless sheep welfare is at risk; or
2) on sheep less than three months old unlesstheir sheep welfare is at risk;
or
3) on sheep that are unable to move away; or
4) in an unreasonable manner on sheep.
S5.5
A person must not trim or grind the teeth of sheep.
S5.6
A person must not alter the anatomy of the prepuce of sheep by incising the
surrounding *skin* (pizzle dropping).
Page | 48
S5.7
A person in charge must ensure that tethered sheep are able to exercise
daily.
The following changes to standards were suggested: (please note numbering may be
out in this chapter)
I/d
Submitted Suggested Revision
by
S5.1
Various
Replace “reasonable” with “appropriate” (LSSA)
Insert “or carry” to S5.1 (1) (LSSA)
No dropping or dragging at all (RSPCA, AA,
others)
No striking at all (Evans, RSPCA, AA, ALQ,
PETA, Sentient, Saklani et al)
S5.1(3) is unclear (AVA) - Remove “in an
unreasonable manner” (PETA, AA)
S5.1(4) - Remove “that are not standing” (PETA,
MacLaren)
Convert to a Guideline (NSW Farmers, SCA) –
actions listed are already covered by cruelty
legislation and the list omits several other
unacceptable practices??
Unnecessary – covered by S1.1 (NSW Farmers,
SCA)
Should finish with the word “manner” –
remainder converted to Guidelines (WPA)
S5.1 A person must handle sheep in a
reasonable manner and must not:
1) lift off the ground by only one leg, or by the
head, ears, horns, neck, tail or wool, unless in
an emergency; or
2) throw or drop, except to land on its feet from
a height less than one metre; or
3) strike in an unreasonable manner, punch or
kick; or
4) drag sheep that are not standing by only one
leg, except in an emergency to allow safe
handling, lifting, treatment or humane killing;
or
5) drag by only the ears, or tail, or wool; or
6) drag by mechanical means, except in an
emergency, for the minimum distance to
allow safe handling, lifting, treatment or
humane killing.
The first revision is in relation to S5.1 – a further
two options developed by the writing group are
Recommendation /
Action Taken / Revised
Content
Agreed add “only” to
S5.1.5 to avoid
confusion, and more
misinformation, the
standard needs to be as
clear as possible and not
hinder current practices
such as shearing and the
use of a cradle to handle
lambs.
‘Carry’ is covered by ‘lift’.
These suggestions do
not recognise practical
aspects of sheep
handling that are often in
the best interests of the
sheep.
Use of ‘reasonable’ dealt
with in chapter one.
Sheep industry states
standard is too
descriptive. LTS
equivalent standard.
Agreed leave as is, as
the argument to remove
was philosophical
argument. Standard
provides clarity,
direction, consistency.
Agreed to address
industries concerns take
at RG.
The SRG did not support
the proposed new
standard S5.1A or the
simplified S5.1B.
SRG did agree to split
standard S5.1 into two
standards for clarity.
Page | 49
I/d
Submitted Suggested Revision
by
presented below. Some of this material will be
deleted from the final report. S5.1A is proposed
by AHA as an intermediate option based on Land
Transport standard SA5.7 and Cattle S5.1.
S5.1A A person must handle sheep in a
reasonable manner and must not:
1) *lift* off the ground by only one leg unless the
sheep is less than 15 kilograms live weight , or by
the head, ears, horns, neck, tail or wool, unless in
an *emergency*; or
2) throw or drop, except to land on its feet from a
height of less than one 1.5 metres; or
3) strike in an unreasonable manner, punch or
kick; or
4) drag sheep that are not standing except in an
emergency for the minimum distance to allow
safe handling, *lifting*, treatment or humane
killing.
S5.1B is proposed by SCA and WPA in
conjunction with a new guideline G5.1A.
S5.1B A person must handle sheep in a
reasonable manner.
S5.2
Various
Mandate muzzling with basket muzzles while
working (RSPCA, Sentient, Saklani et al)
Recommendation /
Action Taken / Revised
Content
SRG agreed the removal
of wool and the height
change to 1.5metres.
RSPCA did not support
this change.
No further action was
agreed
Delete “habitually” or mandate muzzles when
working sheep (Evans)
S5.3
WPA,
WAFF
Remove or reword. WAFF: “Unless there is a
great deal of science backing the 250mm in
length rule, the words should be changed to “a
person in charge must ensure a sheep is shorn at
a time that is appropriate for its breed”.
Agreed change to allow
for all sheep breeds and
wool length.
SRG supported.
“and production system” (WPA)
S5.3 A person in charge must ensure a sheep is
shorn before the wool length is greater than twice
the average annual growth for that breed.reaches
250 mm in length
S5.4
Various
Ban electric prodders (Evans, RSPCA, WSPA,
AA, ALQ, PAM, Sentient, Saklani, ALC)
Use only for welfare or in emergency (PETA)
No further action was
agreed - Relates to
repeated ineffective use
S5.4(4) – “unreasonable manner” is ambiguous
(LSSA)
Page | 50
I/d
Submitted Suggested Revision
by
S5.4 A person must consider the welfare of
sheep when using an electric prodder, and must
not use it:
1) on genital, anal or udder or facial areas of
sheep; or
2) on facial areas, unless sheep theirwelfare is at
risk; or
Recommendation /
Action Taken / Revised
Content
When you need release
a jam up animals in a
race.
SRG supported.
SRG agreed to change
“their” to “sheep”.
2)3) on sheep less than three months old unless
sheep welfare is at risk ; or
SRG agreed to add
“unless sheep welfare is
at risk” to 2nd point.
3)4) on sheep that are unable to move away;
or
RSPCA does not agree
to this change.
4)5)
in an unreasonable manner on sheep.
S5.5
PGAWA,
WAFF,
several
individual
producers
Remove – valuable management tool prolongs
life.
No further action was
agreed - Illegal in most
states and science
shows no long term
positive welfare.
S5.7
Various
Ban permanent tethering or for “long periods”
(QDAFF, Evans, RSPCA, WSPA, AA,
SCTRLHC, ALC, General public)
No further action was
agreed
This standard should additionally specify that
tethered sheep must be inspected daily (TAS
DPIWE).
Should additionally mandate “continuous
access to water and appropriate grazing
vegetation” (Sentient)
Support existing wording (AgForce, WPA)
Support Variation C4 (WAFF)
Tethering Vic
definition
The securing of an animal to an anchor point to
confine it to a desired area. It is not short term
tying up or hobbling.
No further action was
agreed
New
Standard
A person in charge must ensure that wool is
removed from the face of a sheep, if the sheep is
unable to see.
No further action was
agreed
Evans
Revisions to three standards have been recommended in this chapter by the writing
and reference groups in response to the submissions. This is not believed to add any
cost to current sheep enterprises.
Page | 51
The first revision is in relation to S5.1. After much discussion by the reference group
it was decided to create a separate standard for handling as proposed by SCA and
WPA and to revise the remaining points.
S5.3 has been revised to more accurately reflect a feasible regulatory measure that
is desirable for sheep welfare.
S5.4 has been revised to allow the use of electric prodders on facial areas, where
sheep welfare is at risk, after much discussion. This means that where it is necessary
to ‘back up’ sheep in a race way if there is a pile up or like situation, then it is
permissible to use the prodder on a facial area having due regard for avoiding the
eyes. This provision is also relevant to the The Australian Animal Welfare Standards
and Guidelines for the Land Transport of Livestock and if accepted, should figure in a
future revision of the The Australian Animal Welfare Standards and Guidelines for the
Land Transport of Livestock.
C4: ban permanent tethering– See sections A3.4 of the Consultation RIS.
In relation to the matters raised in the RIS variations, the following explanation is
offered;
Variation
Action
Comment
C4: Tethering ban
Not supported as a
standard.
Supported for inclusion in
RIS option C.
RIS survey question 69 (RIS Q24) - Do you believe that the benefits likely to be
achieved under Variation C4 of Option B, including the welfare benefits of banning
tethering of sheep and reduction in excess regulatory burden, are justified?
No. of responses
% Agree
% Disagree
% Neutral
89
65
12
12
In general it is believed that tethering is not a significant threat to the welfare of
sheep if properly managed as required by the proposed standard S5.7. Tethering is a
minority practice that does not warrant further regulatory action.
The following changes to guidelines were suggested:
I/d
Submitted
by
G5.1A
SCA, WPA
Suggested Revision
G5.1A A person handling sheep should:
Recommendation /
Action Taken / Revised
Content
SRG did not support this
guideline.
Page | 52
I/d
Submitted
by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
 Only *lift* the sheep off the ground by only one
leg, or by the head, ears, horns, neck, tail or
wool, in an extreme *emergency*,; or
 Allow a sheep to land on its feet if dropped
from a height more than one metre; or
 Avoid striking, punching or kicking sheep to
any extent; or
 Only drag sheep that are not standing by only
one leg, to allow safe handling, *lifting*,
treatment or humane killing in an extreme
emergency; or
 Only drag sheep by the ears, tail or wool in an
extreme emergency; or
 Only drag sheep (that are not standing) by
mechanical means, for the minimum distance
to allow safe handling, *lifting*, treatment or
humane killing in an extreme *emergency*.
SRG G5.3
Robinson
Self-contradictory
G5.3 Sheep should be restrained and isolated for
the minimum time necessary. Sheep isolated in a
pen should be provided with a pen mate or a
mirror.
SRG
G5.3a
SRG
A person tethering sheep should:
 ensure the tether is long enough to allow
adequate exercise and grazing
 ensure the tether does not become entangled
 inspect the sheep a minimum of once per day
Numerous
Various

not tether sheep by the leg or foot

ensure sheep have adequate shelter.
G5.5 Upgrade to a Standard (Vic DEPI)
G5.7 – first part should be a Standard (Vic DEPI)
– replace with “A person in charge must not
overcrowd sheep in a pen, race or yard and must
ensure the sheep are freely able to move, turn
SRG agreed to add “or a
mirror” as per Australian
Code.
Agreed new standard as
per in line with cattle.
As requested in meeting
David Champness has
drafted new guidelines
for consideration.
No further action was
agreed
Page | 53
I/d
Submitted
by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
around, or rise from a lying position unobstructed
in a pen or yard”
G5.15 should be converted to a Standard (ALC,
WSPA, Saklani et al)
G5.2, G5.15, G5.17, G5.19-G5.22 – convert to
Standards (RSPCA SA) – G5.10 also (PAM) –
G5.13-5.14 as well (MacLaren) – WSPA, Evans
similar.
Majority of Section 5 Guidelines should be
Standards (Sentient)
G5.17 should be a Standard – add “or ram
harness” (Vic DEPI)
G5.20 Should be promoted to an enforceable
Standard and specify that (1) shearing must not
occur if cold, wet or windy weather occurs or is
expected and adequate shelter is not available;
and (2) newly shorn sheep must be provided with
shelter, food and water sufficient to meet all
welfare needs.
G5.16
RSPCA
Remove reference to earmarking.
G5.16 Earmarking, tattooing, tagging and
vaccination should be done in a way that
minimises the risk of infection and with
instruments that are sharp and clean.
G5.19
PETA
Should be accompanied by a Standard
specifically dedicated to the handling and
treatment of sheep before, during and after
shearing.
No further action was
agreed
No further action was
agreed – considered
covered in other
guidelines.
G5.19 Care should be taken when shearing and
crutching to minimise cuts, and severe cuts
should be treated at the first reasonable
opportunity.
G5.20
Should be promoted to an enforceable
Standard and specify that (1) shearing must not
occur if cold, wet or windy weather occurs or is
expected and adequate shelter is not available;
and (2) newly shorn sheep must be provided with
shelter, food and water sufficient to meet all
welfare needs.
No further action was
agreed - risk
management issue.
Page | 54
I/d
Submitted
by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
G5.20 When harvesting wool, consider:
G5.21
Vic DEPI

stopping if cold, wet and windy weather is
experienced or predicted and adequate
shelter is not available

releasing newly shorn sheep into adequate
shelter or allowing sheep to remain in the
shed until the risk has passed

ensuring there is adequate feed and water
available for newly shorn sheep.
Ram sedation – potentially in conflict with Vic
POCTA.
Agreed add “and” for
better English.
G5.21 Rams that are sedated for shearing or
crutching should be managed to prevent
exposure, sunburn and smothering and in
accordance with the directions of the prescribing
veterinarian.
SRG supported.
One small revision to the guidelines have been recommended by the writing group in
this chapter in response to the submissions.
Page | 55
Chapter 6 Tail Docking and Castration
S6.1 A person performing tail docking or castration must have the relevant
knowledge, experience and skills, or be under the direct supervision of
a person who has the relevant knowledge, experience and skills.
Tail docking
S6.2 A person must not *tail dock* sheep that are more than six months old
without using appropriate *pain relief* and haemorrhage control for the
sheep.
S6.3 A person must leave a docked tail stump of a sheep with at least two
one *palpable free joints* remaining.
Castration
S6.4 A person must not *castrate* or use the cryptorchid method on sheep
that are more than six months old without using appropriate *pain relief*
and haemorrhage control for the sheep.
The following changes to standards were suggested:
I/d
Submitted Suggested Revision
by
S6.1
Various
“Community expectations” are that these
operations should be performed by (or under the
supervision of) a veterinarian (Saklani and
followers)
Recommendation /
Action Taken / Revised
Content
No further action was
agreed
All invasive procedures must be done by
veterinarians, with pain relief in all ages
(Sentient).
S6.2 and Various
S6.4
Necessary invasive procedures must be
performed with pain relief irrespective of age
(All welfare/rights groups, Evans, many individual
submissions, general public ) – ie delete “that are
more than 6 months old”
Mandate pain relief in all ages by 2015
(RSPCA)
“Little evidence supports the notion that animals
at an early age suffer less than those that are
older or adult” (Windsor – Sydney Uni)
3 months (PAM)
No further action was
agreed - Extensive
impracticability of pain
relief noted agreed to go
to RG and most likely
higher.
Impractical due to pain
relief registration –
agreed no room to move
due to states. NSW ACT
already states vet only.
Page | 56
I/d
Submitted Suggested Revision
by
Castration by rubber rings only under local
anaesthetic provided by veterinarian – if
>6months surgical by a veterinarian (Craddock Vet)
Tail docking by hot knife or rubber rings only
– up to 6 months under local anaesthetic
(Craddock - Vet)
Research results show ring castration is more
painful than surgical castration with pain relief
(Windsor)
Recommendation /
Action Taken / Revised
Content
Standards reflect current
Acts.
Agreed to add “for the
sheep” at the end of the
standard for completion.
SRG supported the
changes and agreed to
add “appropriate”.
S6.2, S6.4 impractical – no pain relief is
“economic, effective and registered” (PGAWA,
WAFF) – convert to a Guidelines (WAFF, WPA)
S6.4 – “cryptorchid” should be replaced by
“cryptorchidism” (SCA)
S6.2 A person must not tail dock sheep that are
more than six months old without using pain relief
and haemorrhage control for the sheep.
S6.4 A person must not castrate or use the
cryptorchid method on sheep that are more than
six months old without using pain relief and
haemorrhage control for the sheep.
S6.3
Various
Insert “dock the tail through the joint space and”
before “leave......” (Evans, RSPCA SA, WSPA,
PAM)
Industry support one joint
not two – 3 joints best
practice.
Amend to “one free palpable joint” (WPA)
Science stated 1 vs. 2
not much difference in
measureable welfare.
Convert S6.3 to a Guideline (AWI) – not
practical to be prescriptive....better to include 3
joints in G6.20
Unenforceable – producers cannot guarantee
length and too many field errors – RIS states no
welfare benefit (Craig, Marriott, Silcock, SCA)
WG AGREED to change
to one.
SRG supported.
Objective unclear – 3 joints is optimum – no
evidence two is better (PGAWA, SCA)
One joint or two is acceptable (WAFF)
Replace with 2 Standards – one mandating
G6.20 for breeders and Variation C6 for slaughter
lambs(Vic DEPI)
Page | 57
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken / Revised
Content
No scientific support for two joints over one
(NSW Farmers, SCA – i.e. support Variation C6)
S6.3 A person must leave a docked tail stump of
a sheep with at least one two palpable free joints
remaining.
New
standard
LSSA
New standard is required to prevent concurrent
tail docking and castration.
No further action was
agreed
New
standard
AA
New standard S6.2 (a)/6.4(a): ‘Tail docking and
castration must be accompanied by available
registered pain relief measures’.
No further action was
agreed
New
standard
RSPCA
New standard is required to prohibit tail docking
of lambs destined for slaughter.
An assured market does
not exist in Australia.
General
issues
Welfare
groups,
vets,
General
public
Necessary invasive procedures must be
performed with pain relief irrespective of age.
All invasive procedures must be done by
veterinarians, with pain relief in all ages
(Sentient)
Ban invasive procedures where the ultimate
benefit is measured in convenience of the
operator (HSI).
No further action was
agreed, not practically
achievable.
General
issues
Producer
groups
Pain relief is impractical, labour intensive,
expensive, short-term and limited value.
Pain management is over days or weeks.
Allowing animals to good quality feed, minimising
time that lambs spend away from their mothers
and ensuring that procedures are done quickly
and cleanly are far more effective for pain
management than the administration of a drug.
The age of a sheep is not easily measurable and
therefore it will be difficult to impossible to
enforce any standard which has an age limit. An
alternative and measurable age limit may be
when sheep get their adult teeth (NSW Farmers).
No further action was
agreed, states legislation
in place.
Agreed convenience of
the operator often has
positive welfare
implications.
Issue of pain relief noted
and agreed to go to RG
and most likely higher for
resolution.
Three revisions to the standards have been recommended in this chapter by the
writing and reference groups in response to the submissions. This is not believed to
add any cost to current sheep enterprises.
S6.2 has been revised for clarification.
S6.3 has been revised to only require one free palpable tail joint to remain after tail
docking.
Page | 58
S6.4 has been revised for clarification.
C6: Require docked tails to have at least one free palpable joint – See sections
A3.6 of the Consultation RIS.
In relation to the matters raised in the RIS variations, the following explanation is
offered;
Variation
Action
Comment
C6: Require docked tails
to have at least one free
palpable joint
Supported.
No longer required in the
RIS.
RIS survey question 71 (RIS Q26): Do you believe that the benefits likely to be
achieved under Variation C6 of Option B including the welfare benefits of mandating
one free palpable joint with respect to tail-docking procedures and a reduction in
excess regulatory burden, are justified?
No. of responses
% Agree
% Disagree
% Neutral
87
73
10
17
In general it is believed that one free palpable free joint vs. two palpable free joints
holds no welfare difference and is not a significant threat to the welfare of sheep if
properly managed as required by the proposed standard S6.3.
The following changes to guidelines were suggested:
I/d
Submitte
d by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
Numero
us
Various
Upgrade to a standard
No further action was
agreed
G6.2 to a Standard (RSPCA SA, WSPA, PAM,
Vic DEPI, Evans)
Convert G6.3 to a Standard (LSSA) – i.e. S6.2
and S6.4 should set an age limit of 3 months
Convert G6.22 to a Standard (LSSA, RSPCA,
ALQ, ALC, Saklani); - add a ban on tail-docking
as well (MacLaren)
Convert G6.8, G6.10, G6.11, G6.13, G6.16,
G6.18 and G6.21 to Standards (Evans, RSPCA
SA, WSPA) - and G10.14, G10.17 (PAM) and
G6.5, G6.7 and G6.8 (PETA)
Convert G6.5 to a Standard (WSPA)
Mandate G6.20 (Tas DPIWE, RSPCA, Saklani)
Page | 59
I/d
Submitte
d by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
Majority of Section 6 Guidelines should be
Standards (Sentient).
G6.4
SRG
Delete “to” and replace with “of”.
Tail docking, castration and other marking
procedures should be planned with consideration
of to the age of lambs, weather, staff availability
and facilities, including the use of temporary or
permanent yards.
G6.7
Vic DEPI
Omits an abundance of other diseases worthy of
mention in a welfare guideline.
G6.7 Operators should adopt appropriate
strategies to minimise the risk and impact of
common infections, such as by Erysipelothrix
rhusiopathiae and Clostridium tetani, through
vaccination of lambs and/or their mothers.
WG Agreed to delete
examples as too
descriptive.
SRG supported.
G6.16
Robinson
Replace “mustered and yarded” with “driven or
yarded”.
G6.16 After placement in paddocks, lambs should
not be forcibly mustered and yarded until wounds
are healed.
No further action was
agreed
New
Guidelin
e
JE Watts
Guideline recommending farmers adopt selection
techniques for short-tailed sheep.
No further action was
agreed
New
SRG
guideline
G6.22a A person should use the most appropriate
tools and least painful method to castrate sheep
that is applicable to the production system.
Definitio
n
Change definition “cryptorchidism” to cryptorchid.
SRG
Agreed by SRG for
correctness.
One revision to the guidelines has been recommended in this chapter by the writing
group in response to the submissions.
Page | 60
Chapter 7 Mulesing
S7.1 A person performing* mulesing* must have the relevant knowledge,
experience and skills, or be under the *direct supervision* of a person
who has the relevant knowledge, experience and skills.
S7.2 A person must not *mules* sheep that are less than 24 hours old or
more than 12 months old.
S7.3 A person must not *mules* sheep that are 6–12 months old without
using *pain relief*.
S7.4 A person must not *mules* sheep showing signs of debilitating disease,
weakness or ill-thrift.
S7.5 A person *mulesing* sheep must only remove wool-bearing skin.
The following changes to standards were suggested:
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken / Revised
Content
S7.1
Various
Unenforceable – no available means of
assessing competency (LSSA)
Operator should be under the supervision of,
or trained by, a veterinarian (Saklani)
“Mulesing must only be performed by a
registered veterinarian using appropriate
anaesthesia and analgesia” (Sentient)
Mulesing contractors should be trained and
accredited (BAAA,de Fraga, LCA)
Abandons the existing MCOP requirement for
a formal accreditation process (Vic DEPI,
RSPCA, AA, Edgar’s Mission)
Omit “or be under the direct supervision of”
(RSPCA)
No further action was
agreed
S7.2
Various
Between 2-12 weeks only (i.e. elevate G7.6 to a
Standard - RSPCA, ALC, PAM, Saklani)
24H-12 weeks ( Evans, RSPCA SA)
24H-8 weeks (WSPA)
24H-4 months (Sentient)
Support 12 months (AgForce) “Variation C2
provides no flexibility for the small proportion of
producers who, due to genuine external
constraints such as incomplete musters in
pastoral areas or seasonal conditions resulting in
No further action was
agreed
Page | 61
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken / Revised
Content
a heavy fly attack, cannot safely mules all lambs
before the age of 6 months”.
Support 12 months (AWI, Glanna, WAFF) –
Variation C2 would put producers at risk of
breach of S1.1, 3.1, 3.3 and 7.4 in seasons of
extreme weather or natural disasters and for
some producers, force mulesing during peak
flystrike period.
12 month ‘cut-off’ is an ambit age point - if
done well with pain relief, there is no need for an
age limit (Windsor) – dispute basis of G7.6
Add “except in exceptional circumstances”
(WAFF).
S7.3
Pain relief regardless of age (Variation C1RSPCA, AA, WSPA, BAAA, ALC, PAM, Evans,
General public, others)
Benefits very few sheep – most mulesing is
done <6 months
Operators/ research evidence equal or more
pain in younger sheep (Windsor, Animal Ethics,
Glanna station)
Little evidence that pain level is lower in
sheep less than 6mths (Windsor, AVA)
Tri-Solfen (S4*) is the only registered product –
must be under veterinary supervision which is
not practical in all circumstances (AgForce,
WPA, PGAWA)
Tri-Solfen works and should be used in all
ages (Glanna Merino Stud); high animal welfare
benefits, better incentive to phase out mulesing,
other benefits (Animal Ethics)
RIS argument for pain relief for castration (S6.4)
could be applied to mulesing – i.e. contractor
use acceptable (PGAWA)
Oppose Variation C1 – impractical, too costly
(WAFF)
*Tri-Solfen is now S5
No further action was
agreed
Discussed under RIS
variation C1 below.
S7.5
Insert “not perform a radical mules operation
and” after “must” (Vic DEPI)
Add “and the minimum required to achieve
flystrike protection” (i.e. G7.5 - Evans)
Remove S7.4 and S7.5 – already covered by
S1.1 and S7.1 (NSW Farmers).
No further action was
agreed
Page | 62
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken / Revised
Content
New
Standard
RSPCA
Mandate breeding and selection for resistant
conformation.
No further action was
agreed
New
Standard
AA
Lambs for slaughter before 12 weeks old, or the
onset of puberty, must not be mulesed.
No further action was
agreed, An assured
market does not exist in
Australia.
General
issues
Various
Many welfare/rights and lawyer groups (AA,
PETA, ALQ, Sentient, Animal Liberation SA,
BAAA¹, and ALC) called for a ban on mulesing
and/or promoted /demanded mandatory
pursuit of alternatives for flystrike control.
No further action was
agreed
General
issues
PETA
The mulesing standards should be amended so
that:
No further action was
agreed
The various matters currently mandated in
MCOP mulesing Appendix be afforded the
status of standards.
Sanction-reinforced deadlines require the good
faith pursuit of regulatory approval for adequate
long-lasting pain relief options.
The note below the Standards be removed and
replaced with “Mulesing is considered to include
removal of skin from the breech using shears,
injections and clips”.
Mulesing WPA
Definition
New definition suggesting remove “and/or tail”.
As tail modification is common.
Mulesing (mules, mulesed) - The removal of skin
from the breech and/or tail of a sheep using
mulesing shears.
WG Agreed No change.
International parity –
problem.
SRG did not support –
agreed no change to
original version.
No change the standards recommended by the writing group. A revision to the
Mulesing definition has been recommended by the writing group in this chapter in
response to the submissions. This is not believed to add any cost to current sheep
enterprises.
In relation to the matters raised in the RIS variations, the following explanation is
offered;
Page | 63
Variation
Action
Comment
C1: All Mulesing with pain
relief
Not supported as a
standard.
Supported for inclusion in
RIS option C.
C2: Restrict Mulesing age
to less than 6 months of
age
Not supported as a
standard.
Supported for inclusion in
RIS option C.
C1: All Mulesing with pain relief – See sections A3.1 of the Consultation RIS.
RIS survey question 66 (RIS Q21) – Do you believe that the benefits achieved under
Variation C1 of Option B, including the welfare benefits of pain relief with all mulesing
and reduction in excess regulatory burden, are justified?
No. of responses
% Agree
% Disagree
% Neutral
89
77
17
6
In general it is believed that pain relief for all mulesing will provide benefits for sheep
subjected to the mules operation but was lacking the support of WoolProducers
Australia. The availability of the registered pain relief agent Tri Solfen, will be made
more freely available as an S5 in early 2014.
In general it is believed that the extension of the use of pain relief for all mulesing
should not be mandated if mulesing is properly managed as required by the
proposed standards S7.1 to S7.5. The sheep industry recognises the need to
minimise the use of surgical mulesing and is committed to a significant investment in
research for the adoption of alternative non-surgical methods.
C2: Restrict Mulesing age to less than 6 months of age - See sections A3.2 of the
Consultation RIS.
RIS survey question 67 (RIS Q22) Do you believe that the benefits likely to be achieved
under Variation C2 of Option B, including the welfare benefits of requiring mulesing to
be performed under 6 months of age and reduction in excess regulatory burden, are
justified?
No. of responses
% Agree
% Disagree
% Neutral
82
77
15
8
In general it is believed that restricting the age of mulesing to less than 6 months of
age will deprive the sheep industry of necessary flexibility to deliver welfare benefits
to a select portion of the sheep flock that varies according to seasonal weather
patterns.
In general it is believed that the continuation of mulesing to 12 months of age with
pain relief if properly managed as required by the proposed standards S7.1 to S7.5
Page | 64
will be an acceptable sheep welfare outcome. The sheep industry recognises the
need to minimise the use of surgical mulesing and is committed to a significant
investment in research for the adoption of alternative non-surgical methods.
The following changes to guidelines were suggested:
I/d
Submitted
by
Suggested Revision
Recommendation /
Action Taken /
Revised Content
Objective
Evans
Amend to:
“In circumstances where mulesing is
necessary for the long-term welfare of
the sheep INSERT ‘and non-surgical
alternatives cannot be implemented’,
it is done in a manner that minimises
the impact of the procedure.
No further action was
agreed
Numerous
Various
Upgrade to standards
No further action was
agreed
G7.8 – pain relief is always available
– should be elevated to a Standard
(RSPCA, PETA, AA, Saklani, Evans)
G7.1, G7.7 to Standards (with
amendments – PETA)
G7.1, G7.7, G7.12, G7.17, G7.18 and
G7.20 – convert to Standards
(RSPCA SA, WSPA) – add G7.9
(PAM) - similar suggestions from
Evans and Sentient.
G7.18
Robinson
Replace “mustered and yarded”
with “driven or yarded”.
No further action was
agreed
G7.18 After placement in paddocks,
lambs should not be forcibly mustered
and yarded until wounds are healed.
New
Guideline
NSW
Farmers
A new guideline should also be added
before G7.5 which reads: “Where it is
appropriate to the conformation of the
lamb being treated to achieve flystrike
protection, tail stripping should be
considered in preference to
mulesing”. The addition of tail
stripping and this guideline will
maximise welfare outcomes by
ensuring that mulesing is only
performed when necessary.
No further action was
agreed, Mulesing
definition not
amended.
Page | 65
I/d
Submitted
by
Suggested Revision
Recommendation /
Action Taken /
Revised Content
General
issues
Andrew
Wood
(NSW
Farmers,
Armidale)
“The complexities of individual microclimates, the need for flexibility in
timing of mulesing operations to
enhance rapid recovery and promote
best practice, are all factors that are
taken into consideration when timing
this key procedure to minimise fly
strike deaths.
No further action was
agreed
Flexible, best practice management
options must remain open for farmers
to adapt to changing environmental
conditions with respect to responsible
animal welfare.”
Page | 66
Chapter 8 Breeding Management
S8.1 new A person performing artificial breeding procedures on sheep must
have the relevant knowledge, experience and skills, or be under the
*direct supervision* of a person who has the relevant knowledge,
experience and skills.
S8.1 A person performing artificial breeding procedures on sheep must not
cause unreasonable pain, distress or injury to sheep.
S8.2 A person must be a veterinarian, or operating under veterinary
*supervision*, to perform surgical embryo transfer and laparoscopic
insemination of sheep.
The following changes to standards were suggested:
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken / Revised
Content
S8.1
Various
No further action was
agreed
Define “artificial breeding procedures” in the
Glossary (LSSA)
Remove “not cause unreasonable pain” and
replace with “take action to minimise any”(LSSA,
Evans) or “make every effort not to cause any”
(MacLaren)
“unreasonable” is subjective and undefined –
elevate G8.14 to a Standard (Variation C5 RSPCA, AA, ALC, Saklani et al, Vic DEPI)
Support existing wording (Agforce, WAFF) –
welfare is covered by existing wording.
S8.2
Various
New
Vic DEPI
Standard
Exclusively vet only (Evans, RSPCA SA, ALQ,
WSPA)
Or acting under direct supervision by a
veterinarian (Sentient, Vic DEPI)
Support existing wording (AgForce)
Oppose – technicians in Tasmania highly trained
and AVA certified (TFGA).
No further action was
agreed
To require persons performing AB procedures to
have relevant knowledge, skills and
experience etc...(Elevate G8.12 training and
competency).
A person performing artificial breeding
procedures on sheep must have the relevant
knowledge, experience and skills, or be under the
*direct supervision* of a person who has the
relevant knowledge, experience and skills.
WG Agreed new
standard.
SRG supported.
Page | 67
One new standard has been recommended by the writing and reference groups in
this chapter in response to the submissions.
A new S8.1 has been recommended to reflect the concerns about the risks to the
welfare of sheep subjected to artificial breeding procedures, consistent with other
surgical procedures for sheep. This is not believed to add any cost to current sheep
enterprises.
C5: Mandate pain relief for ET/LAI – See sections A3.5 of the Consultation RIS.
In relation to the matters raised in the RIS variations, the following explanation is
offered;
Variation
Action
Comment
C5: Mandate pain relief
for ET/LAI
Not supported as a
standard.
Supported for inclusion in
RIS option C.
RIS survey question 70 (RIS Q25) - Do you believe that the benefits likely to be
achieved under Variation C5 of Option B, including the welfare benefits of mandating
pain relief for laparoscopic artificial insemination (LAI) and embryo transfer (ET) and a
reduction in excess regulatory burden are justified?
No. of responses
% Agree
% Disagree
% Neutral
87
75
13
12
In general it is believed that the extension of the use of pain relief for all artificial
breeding procedures does not provide sufficient benefit for ewes if properly managed
as required by the proposed standards S8.1, S8.2 and S8.3. The sheep industry
recognises the value of artificial breeding to maximise genetic progress and is
committed to a significant investment in research for the adoption of better adapted
sheep.
The following changes to guidelines were suggested:
I/d
Submitt
ed by
Suggested Revision
Recommendation /
Action Taken /
Revised Content
G8.1
SRG
Change technicians to persons
agreed
Technicians Persons responsible for
breeding management should have an
understanding of reproduction and
behaviour of both the ewe and the ram.
G8.4
SRG
Delete “and” and add “but”.
agreed
Page | 68
I/d
Submitt
ed by
Suggested Revision
Recommendation /
Action Taken /
Revised Content
G8.4 Lambing ewes should be
monitored, and but disturbed as little as
possible.
G8.5
Vic DEPI
Upgrade to a Standard – otherwise
conflict with S3.3 and cruelty legislation.
No further action was
agreed
G8.5 Ewes that receive severe injuries
during lambing or that are affected by a
severe adverse outcome (prolapsed
uterus, unable to remove lamb) should
receive urgent treatment or be humanely
killed without delay.
G8.9
G8.12
Vic DEPI
WG
Upgrade to a Standard – otherwise
conflict with POCTA.
WG Agreed – add
“without delay”.
G8.9 Weak or orphaned lambs with very
little chance of survival should be
humanely killed without delay.
SRG supported.
Agreed not considered needed.
WG Agreed delete
G8.12 Technicians conducting artificial
insemination, embryo transfer or electroejaculation of sheep should be trained
and competent in these techniques.
SRG Supported
G8.13
WG
Moved positions under “Rams” heading.
Agreed
General
WG
Slight revision in sub heading changes
WG Agreed
SRG supported
Numerous
Various
G8.13 – upgrade to a Standard to
prohibit electro-ejaculation (Evans,
RSPCA, ALQ, ALC)
G8.3-8.9, G8.14 should be Standards
(Evans)
No further action was
agreed
Guideline G8.13
relocated to section
on rams
G8.1, G8.5-8.7, G8.9 and G8.14 –
convert to Standards (RSPCA SA) – add
G8.3-4, 3.6, 3.8 (PAM, WSPA) - include
G8.3, 8.10 and 8.12 (Sentient).
Several revisions to the guidelines and one deletion has been recommended in this
chapter in response to the submissions.
Page | 69
Chapter 9 Intensive Sheep Production Systems
S9.1 A person in charge must ensure that feed and water is available daily to
sheep in *intensive production systems*.
S9.2 A person in charge must ensure the daily *inspection* of all sheep in the
first week of confinement, to ensure adaptation to the *intensive
production system*.
S9.3 A person in charge must take reasonable action where sheep have not
adapted to an *intensive production system*.
S9.4 A person in charge must not allow faeces and urine to accumulate to
the stage that compromises the welfare of sheep in an *intensive
production system*.
S9.5 A person in charge must ensure an indoor housing system for sheep
has effective *ventilation*.
S9.6 A person in charge must ensure sufficient space to allow all sheep to
*lie* on their sternums at the same time in an *intensive production
system*.
S9.7 A person must not permanently house a sheep in a single pen for fine
wool production.
A person in charge must ensure a sheep housed in a single pen for fine
wool production is able to turn around, see, hear, smell and touch
neighbouring sheep.
The following changes to standards were suggested:
I/d
Submitted Suggested Revision
by
S9.1
Sentient,
Evans
Mandate Continuous (not “daily”) access to
water
Recommendation /
Action Taken /
Revised Content
No further action was
agreed
Make water access a separate Standard.
Definition
SRG
AHA
intensive
production
systems
An operation where sheep are
confined for a period longer
than four weeks for the
purposes of wool, meat or
milk production, and are
dependent on the daily supply
of feed and or water provided
No further action was
agreed
Page | 70
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken /
Revised Content
by human or mechanical
means.
Does not include rams housed
for breeding, or stud sheep in
preparation for showing or
sheep held in a confinement
area.
S9.2
Sentient
“First month” – not “first week”.
S9.2 A person in charge must ensure the daily
inspection of all sheep in the first week of
confinement, to ensure adaptation to the
intensive production system.
WG Agreed to delete
reference to a
timeframe as the
essential act is daily
inspection, at all stages
of confinement.
SRG supported.
S9.3
Various
Vague – no guide to “reasonable action” (LSSA,
AA) – replace with “appropriate” (Evans)
Reword to “A person in charge must remove
sheep exhibiting signs of sickness, digestive
conditions or injury or stereotypic behaviours
such as repetitive motion, wool biting and
mouthing of railings from the intensive
production system as soon as practicable”
(LSSA).
No further action was
agreed, covered by
G9.11
S9.4, S9.5
Sentient
Prescribe every 24 hours and maximum
ammonia level of 25 ppm
No further action was
agreed
S9.6
Sentient
Amend to allow lateral recumbency (Evans,
RSPCA, AA, ALQ, Saklani) ... add “stand up,
turn around and walk freely...”
No further action was
agreed - no difference
in science between
sternal and lateral
recumbency.
S9.7
Various
Remove and elevate G9.14 to a Standard to
prohibit single penning (Evans, RSPCA, AA,
ALC, Saklani)
SRG agreed a new
standard on banning
single penning. Old
Standard S9.7 deleted
as no longer relevant.
S9.7 and G9.14 are inconsistent (AVA)
Support Variation C3 (WAFF)
S9.7b
SRG
Ban Single penning
SRG agreed.
Page | 71
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken /
Revised Content
S9.7 A person must not permanently house a
sheep in a single pen for fine wool production.
New
Evans
Standard
A person in charge must ensure that
appropriate bedding is provided and
maintained in a hygienic state.
No further action was
agreed
New
Evans
Standard
A person in charge must ensure that water is
constantly available to sheep in intensive
production systems (i.e. amend S9.1).
No further action was
agreed
New
Evans
Standard
A person in charge must ensure that sheep in
intensive production systems are inspected
daily (i.e. amend S9.2).
Agreed.
General
issues
Need to stipulate if and where these Standards
apply to stock containment areas used for
feeding sheep in droughts and floods (Vic DEPI)
No further action was
agreed
Various
This section does not recognise that shedded
sheep are a vastly different production system
to feedlots. The significance of this difference is
such that this should go back to the writing
group and they should develop separate
Guidelines for shedded and feedlot sheep
(NSW Farmers)
Need to define “intensive sheep production
systems” to distinguish them from pre-export
facilities (SCA)
Live export is
excluded, explicit as
stated the definition.
Two revisions to the standards have been recommended in this chapter by the
writing and reference groups in response to the submissions. A revised definition of
intensive production systems is proposed to exclude management confinement
feeding for clarity.
S9.2 has been revised to reflect the need to inspect confined sheep daily to ensure
their welfare needs are met adequately. This is not believed to add any cost to
current intensive sheep enterprises.
C3: Single penning for wool production ban – See sections A3.3 of the
Consultation RIS.
In relation to the matters raised in the RIS variations, the following explanation is
offered;
Variation
Action
Comment
Page | 72
C3: Single penning for
wool production ban
Supported for inclusion as
a standard.
Supported for inclusion in
RIS option C.
RIS survey question 68 (RIS Q23) –Do you believe that the benefits likely to be
achieved under Variation C3 of Option B, including the welfare benefits of banning
single penning of sheep and reduction in excess regulatory burden, are justified?
No. of responses
% Agree
% Disagree
% Neutral
89
71
18
11
It was agreed that single penning for wool production is a minority practice that does
warrant further regulatory action.
The following changes to guidelines were suggested:
I/d
Submitte
d by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
Numero
us
Various
G9.6 - upgrade to a Standard (RSPCA, AA,
ALQ, Saklani)
No further action was
agreed
G9.1-9.4, G9.7-9.8, G9.15-9.19, G9.23-9.27 –
convert to Standards (RSPCA-SA, PAM, Evans,
Sentient)
G9.30 – convert to a Standard (Evans, RSPCA
SA, all other AW/AR groups)
G9.1, 9.7, 9.18, 9.21, 9.23, 9.27, 9.29 and 9.30
should be Standards (Vic DEPI)
G9.1-G9.30 should all be mandatory (MacLaren)
All Guidelines except G9.11, G9.12, 9.20-9.24,
G9.28 should be Standards (WSPA)
G9.14
SRG
G9.14 Sheep should not be housed in single pens
for any longer than is necessary.
It is proposed that this
guideline remains as
amended. It is still
relevant for sheep being
treated and exhibition.
A single revision to the guidelines has been recommended in this chapter in
response to a change in the standard.
Page | 73
Chapter 10 Humane killing
S10.1 A person in charge must ensure killing methods for sheep result in rapid
loss of consciousness followed by death while unconscious.
S10.2 A person killing a sheep must have the relevant knowledge, experience
and skills to kill the sheep humanely, or be under the *direct supervision*
of a person who has the relevant knowledge, experience and skills,
unless:
1) the sheep is suffering and needs to be killed to prevent undue suffering;
and
2) there is an unreasonable delay until *direct supervision* by a person
who has the relevant knowledge, experience and skills becomes is
available.
S10.3 A person in charge of a sheep suffering from severe distress, disease
or injury that cannot be reasonably treated must ensure the sheep is
killed at the first reasonable opportunity.
S10.4 A person killing sheep must take reasonable action to confirm the
sheep is dead.
S10.5 A person killing a lamb by a blow to the forehead must ensure that the
lamb weighs less than 10 kilograms and only when no there is no
firearm, captive bolt or lethal injection reasonably available. there
humane killing methods are reasonably available.
S10.6 A person must only use *bleeding-out* by neck cut to kill a conscious
sheep when there is no firearm, captive bolt or lethal injection
reasonably available.
The following changes to standards were suggested:
I/d
Submitted Suggested Revision
by
S10.2
WG
Replace “is” with “becomes”
S10.2 A person killing a sheep must have the
relevant knowledge, experience and skills to kill
the sheep humanely, or be under the *direct
supervision* of a person who has the relevant
knowledge, experience and skills, unless:
1) the sheep is suffering and needs to be killed
to prevent undue suffering; and
Recommendation /
Action Taken / Revised
Content
WG Agreed - better
English.
SRG supported.
Page | 74
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken / Revised
Content
2) there is an unreasonable delay until *direct
supervision* by a person who has the relevant
knowledge, experience and skills is becomes
available.
S10.3
LSSA
Concerns with “at the first reasonable
opportunity” – undefined and creates strong
defence – as with S3.3
No further action was
agreed
S10.5
Various
Remove S10.5 – all sheep must be stunned
with a firearm or captive bolt irrespective of age
(RSPCA, AA, ALQ, PAM, Sentient, Saklani)
SRG supported change
but agreed to list the
methods.
Convert to a Guideline – “The stated welfare
objective, ‘Where it is necessary to kill sheep, it
is done promptly, safely and humanely’ – is
achieved through S10.1 – S10.4 (WPA, WAFF).
Stipulation of how the objective is to be
achieved (such as in the proposed S10.5, and
also 10.6 – see below) may unnecessarily limit
the options of persons across a broad range of
circumstances which are difficult to foresee”
(WPA)
S10.5 A person killing a
lamb by a blow to the
forehead must ensure
that the lamb weighs
less than 10 kilograms
and only when there is
no firearm, captive bolt
or lethal injection
reasonably available.
Add “and must be done by a single, sharp blow
delivered to the centre of the forehead” (Evans,
Sutton) i.e. incorporate G10.3.
Change to 5 Kg unless moribund or
immobile – then require bleeding out >5 Kg
following loss of consciousness.
Do not limit to 10 Kg – stunning should be
done on all sheep prior to bleeding and most
farmers are strong enough to stun an adult
sheep with a hammer (J Vaughan - vet)
10 Kg limit is valid (Jubb)
S10.5 A person killing a lamb by a blow to the
forehead must ensure that the lamb weighs less
than 10 kilograms and only when no other
humane killing methods are reasonably
available.
S10.6
Various
Amend to apply only in circumstances where
the sheep is suffering and needs to be killed to
prevent further undue suffering (LSSA)
No further action was
agreed
Page | 75
I/d
Submitted Suggested Revision
by
Recommendation /
Action Taken / Revised
Content
Amend to “unless in an emergency” (WSPA)
Add “and the killing is in the welfare interests
of the sheep” (Vic DEPI)
Remove “reasonably” before “treated” –
ambiguous, unnecessary (LSSA)
Remove it altogether (RSPCA) ban all killing
of conscious sheep by neck cut (Sutton)
Convert to a Guideline (WPA, SCTRLHC,
WAFF) – as for S10.5 above
Stunning should be done on all sheep prior
to bleeding and most farmers are strong
enough to stun an adult sheep with a hammer (J
Vaughan - vet)
No further action was
agreed
Exsanguination may often be preferable “due
to ease of access to the carotids and absence
of vertebral artery co-circulation to the brain
meaning the animal loses consciousness almost
instantly. A skilled operator that is aware of the
importance of immediately cutting both carotid
arteries and uses very sharp equipment and
good technique, is likely to be able to induce a
more efficient death for a sheep than the
alternative methods listed” (Windsor).
Serious unintended safety consequences are
possible if this Standard is included. Shooting
can be very dangerous, especially if performed
in confined circumstances or where multiple
animals have to be euthanased promptly (NSW
Farmers, SCA).
Convert to a Guideline (SCA) – “The stated
welfare objective where humane killing is
necessitated, that is ‘Where it is necessary to
kill sheep, it is done promptly, safely and
humanely’ – is achieved through S10.1 –
S10.5.”
New
Jubb
Standard
New Standards should clearly prescribe
approved and non-approved (i.e. unlawful)
killing methods.
No further action was
agreed
Page | 76
Two revisions to the standards have been recommended in this chapter by the
writing group in response to the submissions. This is not believed to add any cost to
current sheep enterprises.
S10.2 has been amended for clarity.
S10.5 has been revised to emphasize the need to use blunt force trauma as a last
resort killing method when other more reliable methods may not be available.
The following changes to guidelines were suggested:
I/d
Submitte
d by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
G10.1
WG
Add The brainstem should be targeted and it lies
midway along an imaginary line drawn between
the base of the ears.
G10.1 The poll method is the preferred method
for killing sheep (see Figure10.1). The brainstem
should be targeted and it lies midway along an
imaginary line drawn between the base of the
ears.
WG Agreed. The dot
point in the diagram
indicates this.
Suggest delete sharp.
G10.3 A single sharp blow should be delivered to
the centre of the forehead.
WG Agreed. ‘Sharp’
deleted as not required
for clarity.
G10.3
WG
SRG supported.
SRG supported.
G10.4
Sentient
Upgrade to a Standard and add “Exemptions
must not be allowed on the grounds of religious
slaughter”.
G10.4 Bleeding out of sheep without pre-stunning
using the neck cut should only be done as a last
resort using a suitable, sharp knife. The cut
should transect both the carotid arteries and both
the jugular veins.
No further action was
agreed
General
issues
Dr T Jubb
New Standards should clearly prescribe
approved and non-approved (i.e. unlawful)
killing methods
No further action was
agreed. Previous
discussions have
covered this aspect.
Approved:

gunshot, captive bolt, blunt trauma to the
head or veterinary administered
intravenous agents

bleeding – but must only be used as a
primary method if the aforementioned
primary methods are unavailable
Non-approved: Methods not approved include:
Page | 77
I/d
G10.1
and
Figure10
.1
Submitte
d by
Dr T Jubb
Suggested Revision

bleeding as a primary method if firearm,
captive bolt or veterinary administered
agents are available,

blunt trauma to animals greater than 10
kg,

drowning, asphyxiation, electrocution

intravenous injection of caustic chemicals
or

any other method that does not result in
rapid loss of consciousness followed by
death while unconscious.
Suggest the recently developed MLA diagrams
be used – they are anatomically correct. The
existing side view diagrams in the draft standards
and guidelines are anatomically incorrect with
respect to positioning of the ears relative to the
brainstem.
The brainstem, which should be targeted, lies
between the ear attachments.
For poll shots a simpler and more easily
remembered recommendation, and one with
consistently better outcome, is to aim between the
base of the ears. This covers both point of entry
and direction of aim.
Recommendation /
Action Taken / Revised
Content
Notes revised.
SRG supported.
SRG agreed to include
the content of the MLA
drawings/diagrams.
Change the
recommendations for the
secondary shot to be
crown – not frontal.
Agreed emphasize the
brain stem is the target.
Delete reference to the frontal shot for sheep.
Dr T Jubb
G10.2
Dr T Jubb
Captive bolt devices
To say the length of the bolt should be
appropriate for the class of sheep is irrelevant.
It is the diameter and velocity of the bolt which
are the important determinants of killing power,
not the length of the bolt.
The important things with captive bolts and
firearms is maintenance and calibre and to be
prepared to immediately repeat the shot if
necessary.
Revised note.
SRG supported.
Confirming death
Revised G10.2
No eye movement, 2. No blink reflex, 3. Fixed
dilated pupils, and 4. No breathing for at least 5
SRG supported
Page | 78
I/d
Submitte
d by
Suggested Revision
Recommendation /
Action Taken / Revised
Content
minutes (3 minutes is too short, some will recover
their breathing after a long delay.
Absence of heart beat and pulse are too difficult
to see, hear or feel reliably in the field, even by
veterinarians. Checking for presence of brain
death by absence of brain reflexes is easier,
simpler and more reliable.
Dr T Jubb
Blunt trauma to the head
I don’t think the centre of the forehead is a good
target. The back of the head is likely to be a better
target because that is where the brainstem lies.
I suggest: “a single sharp blow should be
delivered to the back of the head, directed
between the base of the ears and of sufficient
force to fracture the skull”
Poll position preferred.
Added to G10.1
“The brainstem should
be targeted and it lies
midway along an
imaginary line drawn
between the base of the
ears.”
SRG supported.
Dr T Jubb
Bleeding out
Amend the note to say: “severing the spinal cord
as part of the neck cut is unnecessary and painful
and should not be performed”.
No further action was
agreed, adequately
covered by existing note
to G10.4.
Three revisions to the guidelines and revisions to the notes have been recommended
by the writing and reference group in this chapter in response to the submissions and
subsequent discussions.
Page | 79
APPENDIX 1 - LIST OF NOTED SUBMISSIONS AND
ACRONYMS
Reference Group Members
AA
Animals Australia
AgForce
AgForce Queensland
ALPA
Australian Livestock & Property Agents Association
ALRTA
Australian Livestock & Rural Transporters Association
AMIC
Australian Meat Industry Council
AVA
Australian Veterinarians Association
AWI
Australian Wool Innovation
DEPI VIC
Department of Primary Industries Victoria
DPIPWE TAS
Department of Primary Industries & Water, Tasmania
LCA
Livestock Contractors Association
NSW DPI
Department of Primary Industries NSW
QLD DAFF
Department of Primary Industries Queensland
RSPCA
RSPCA Australia
SCA
Sheepmeat Council of Australia
WPA
Wool Producers Australia
Other organisations making submissions
AACT
Against Animal Cruelty TAS
AASMB
Australian Association of Stud Merino Breeders
AE
Animals Ethics Pty Ltd
ALQLD
Animal Liberation QLD
ALSA
Animal Liberation SA
AWG
Australian Wool Growers Ltd
Page | 80
CAA
Cat Alliance of Australia Inc.
Edgar
Edgar’s Mission
HIS
Humane Society International
LSAV
Livestock Saleyards Association of Victoria
LSSA
Law Society of South Australia
NRCLC
Northern Rivers Community Legal Centre
NSWFA
New South Wales Farmers' Association
NSWYL
NSW Young Lawyers Animal Law Committee
PAM
Port Adelaide Monitors
PETA
PETA Australia
PGA
Pastoralists and Graziers Association
PPC
Paraway Pastoral Company
RASWA
Royal Agricultural Society of WA
RSPCA SA
RSPCA South Australia
Sentient
Sentient – the Vet Institute for Animal Ethics
SMBAWA
Stud Merino Breeders Association of WA
STCRLHC
South Coast And Tablelands Regional Livestock Health Committee
TFGA
Tasmanian Farmers' & Graziers' Association
VA
Vegan Australia
VFF
Victorian Farmers Federation
WAFF MS
WA Farmers Federation Wool and meat Council
WSPA
World Society for the Protection of Animals
Individual submissions
Ruchi Saklani
Alicia Sutton
Page | 81
Carole de Fraga
Chris Heislers
Di Evans
Jim Watts
Peter Windsor
Tristian Jubb
Page | 82
APPENDIX 2 - PICTORIAL REPRESENTATION OF
STANDARDS AND GUIDELINES DEVELOPMENT PROCESS
Page | 83